Urted States Environmental Protection Agency Office of Emergency and Remedial Response EPA/ROD/R02-84/004 September 1984 Superfund Record of Decision: Hudson River RGBs Site, NY ------- TECHNICAL REPORT DATA (Please read Instructions on the reverse before completing) 1. REPORT NO. 2. EPA/ROD/R02-84/004 4. TITLE AND SUBTITLE SUPERFUND RECORD OF DECISION Hudson River PCBs Site, NY 7. AUTHOR(S) 9. PERFORMING ORGANIZATION NAME AND ADDRESS SPONSORING AGENCY NAME AND ADDRESS :.S. Environmental Protection Agency 01 M Street, S.W. ashington, D.C. 20460 3. RECIPIENT'S ACCESSION NO. 5. REPORT DATE 09/2S/P4 6. PERFORMING ORGANIZATION CODE 8. PERFORMING ORGANIZATION REPORT NO. 10. PROGRAM ELEMENT NO. 11. CONTRACT/GRANT NO. 13. TYPE OF REPORT AND PERIOD COVERED Final ROD Report 14. SPONSORING AGENCY CODE 800/00 SUPPLEMENTARY NOTES ABSTRACT During a 30-year period ending in 1977, the Hudson River was contaminated with olychlorinated biphenyls (PCBs) from two capacitor manufacturing plants owned by ne General Electric Company. Field surveys have shown that PCB contamination is ound in 40 submerged sediment hot spots, 5 exposed shoreline remnant deposits, iredge spoils on the banks of the upper Hudson River and in estuary sediments. The remedial alternative selected for this site consists of in-place contain- ,ient of remnant shoreline deposits. This temporary solution includes: covering .ffected areas with an 18-inch thick layer of subsoil followed by a 6-inch layer of .opsoil, grading and seeding the cover to minimize erosion and, if necessary, bank -tabilization to prevent scouring. An alternative to address submerged PCB hot spots .•as not selected at this time because of the lack of existing data to establish that existing technology would be effective and reliable. The State will conduct a -redging demonstration program using funds from Section 116 of the Clean Water Act. .f adequate, the information from this demonstration project will be used to develop .1 remedial action which will address both river sediments and the exposed remnant deposits. Key Words: Dredging, No Action Alternative, PCBs, Containment, Direct Contact, 17. KEY WORDS AND DOCUMENT ANALYSIS a. DESCRIPTORS Record of Decision Hudson River PCBs Site, NY Contaminated media: sw, dredge spoils, river sediments Key contaminants: PCBs 18. DISTRIBUTION STATEMENT b.lDENTIFIERS/OPEN ENDED TERMS None 20. SECURITY CLASS (TIlis page! None c. COSATI Field/Group. AC. 22. PRICE EPA Form 2220-1 (R«v. 4-77) PREVIOUS EDITION is OBSOLETE ------- ROD ISSUES ABSTRACT Site: Hudson River PCBs Site, New York Region; II AA, OSWER Briefing Date; June 6, 1984 SITE DESCRIPTION During a 30-year period ending in 1977, the Hudson River was contaminated with polychlorinated biphenyls {PCBs) from two capaci- tor manufacturing plants owned by the General Electric Company. Field surveys have shown that PCB contamination is found in 40 sub- merged sediment hot spots, 5 exposed shoreline remnant deposits, dredge spoils on the banks of the upper Hudson River and in estuary sediments. Selected Alternative The remedial alternative selected for this site consists of in-place containment of remnant shoreline deposits. This temporary solution includes: covering affected areas with an 18-inch thick layer of subsoil followed by a 6-inch layer of topsoil, grading and seeding the cover to minimize erosion and, if necessary, bank stabilization to prevent scouring. An alternative to address sub- merged PCB hot spots was not selected at this time because of the lack of existing data to establish that existing technology would be effective and reliable. The State will conduct a dredging demon- stration program using funds from Section 116 of the Clean Water Act. If adequate, the information from this demonstration project will be used to develop a remedial action which will address both river sediments and the exposed remnant deposits. ISSUES AND RESOLUTIONS KEY WORDS 1. No remedial action will be taken for the . Dredging Hudson River PCB sediments to mitigate the . No Action primary route of exposure through the Alternative environment (consumption of PCB contami- . PCBs nated fish). Because the effectiveness of available technologies to.dredge PCB con- taminated sediments in a dynamic, riverine environment is not known, a cost-effective alternative was not selected. The infor- mation generated from the State's demon- stration dredging program may be used to develop future remedial measures. -1- ------- Hudson River PCBs Site, New York June 6, 1984 Continued 2. In-place containment of remnant PCB deposits . Containment exposed on the shoreline was selected as a . Direct Contact temporary remedial measure until future . PCBs remedial actions are developed which ad- . Temporary Remedial dress PCB contaminated sediments. This Measure temporary remedial measure will be effec- . Volatilization tive in mitigating the primary public expo- sure pathways of direct contact and volatilization. 3. The option of bank-to-bank dredging of the . Dredging river was rejected because of the severe . Environmental damage it would cause to the river ecosystem. Impacts This option was, therefore>not considered adequate to protect the environment. -2- ------- RECORD OF DECISION Remedial Alternative Selection Site: Hudson River PCBs Site; Glen Falls, New York • * Documents Reviewed; I am basing my decision primarily on the following documents describing the analysis of cost-effectiveness of remedial alternatives for the Hudson River PCBs Site: Feasibility Study - Hudson River PCBs Site, New York, NUS Corporation, April 1984. Staff Summaries and Recommendations. Responsiveness Summary dated September 1984. Description of Selected Options; In-place containment of the remnant deposits by application of a soil covering followed by vegetation. In addition, banks currently unreinforced will be stablized and fences will be erected where appropriate to prevent public access. Evaluation of downstream domestic water quality at Waterford, New York and assessment of various treatment upgrading options if appropriate. Declarations; Consistent with the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), and the National Contingency Plan (40 CFR Part 300), I have determined in-place containment of the PCB contaminated remnant deposits is a cost- effective method to effectively mitigate the most significant threats to health and the environment posed by the remnant deposits, The State of New York has been consulted and agrees with the approved remedy. I have determined that a technologically feasible, cost- effective remedial response to PCB contamination in the riverbed that would be reliable and would effectively mitigate and minimize damage to public health, welfare and the environment is not presently available. ------- - 2 - I have determined that the action taken is appropriate when balanced against the availability of Trust Fund monies for use at other sites. I have also determined that the off-site action of monitoring the downstream water quality at Waterford and assessing the adequacy of its water treatment facility is consistent with the goals and objectives of CERCLA to protect public health, welfare and the environment. / Datfe M. Thomas, Assistant Administrator Office of Solid Waste and Emergency Response ------- Summary of Remedial Alternati ve Select ion Hudson RiveV~PCB_s_j>.ite New York Sit^e I^cation and Descr ipt ion: (see Figures 1 through 3) The Hudson River originates in the Adirondack Mountains in Essex County, New York, and empties into the Atlantic Ocean at the Battery in New York City. The river's 17 major tributaries drain 13,365 square miles of land located in eastern New York State and in parts of Vermont, Massachusetts, and Connecticut. The lower river, from its mouth in the upper New York Harbor to its confluence with the Mohawk River near Albany, is a tidal estuary subject to periodic fluctuations in water level. This 150-mile reach is maintained and regulated as a Federal waterway by the U.S. Army Corps of Engineers to provide waterborne access to the Port of Albany and the New York State Barge Canal. The river above Albany is a high gradient, fresh water stream confined by 15 dams. The 30-mile reach between Albany and Fort Edward is officially under the jurisdiction of the New York State Department of Transportation (DOT). Site H i_s t OJT y: Over a 30-year period ending in 1977, two General Electric (G.E.) capacitor manufacturing plants near Fort Edward and Hudson Falls, New York discharged polychlorinated biphenyls (PCBs) to the Hudson River. Much of the PCBs in the discharges was trapped in sediments behind a 100-year-old dam at Fort Edward. After the removal of the dam in 1973, large spring floods scoured an estimated 1.5 million cubic yards of material from the former dam pool. Subsequent studies have revealed that the discharges, in combination with the removal of the Fort Edward Dam, have ultimately resulted in the dispersal of approximately one million pounds of PCB throughout the entire Hudson River system south of Fort Edward. Today, much of this PCB has either been dredged or washed out to sea so that only 498,000 to 656,000 pounds remain in the river. G.E. is also reported to have placed an additional 528,000 to 745,000 pounds of PCB in upland dumps. These PCBs are not directly related to the Hudson River problem (see Tables 1 and 2). The estimates above represent ranges extracted from various studies. Action brought against G.E. by the New York State Department of Environmental Conservation (NYSDEC) in 1975 resulted in a $7,000,000 program for the investigation of PCBs and the develop- ment of methods to reduce or remove the threat of PCB contamin- ation. Subsequent sediment surveys revealed that the most exten- sive contamination was confined to 40 submerged PCB hot spots ------- - 2 - located in the river between Fort Edward and Albany, and to five exposed remnant deposits located in the former dam pool. PCBs were also found to exist in dredge spoils on the banks of the Upper Hudson River and in sediments of the estuary. Other monitoring data showed that minor quantities of PCBs were being released from river-bottom sediments to the water column and to the air and land adjacent to the river. The detection of PCB contamination in Hudson River fish resulted in a State-mandated ban on all fishing in the Upper Hudson River between Albany and Fort Edward, and in restrictions on commercial and recreational fishing in the Lower Hudson. In addition, it was feared that the continued presence of PCBs might disrupt dredging activities needed to maintain the barge canal and Federal waterways and might curtail the development of the river for hydroelectric!ty. For these reasons, NYSDEC proposed a partial cleanup of the river by dredging selected PCB hot spots (areas of relatively high PCB contamination, generally between 50 and 500 ppm) and containing the contaminated material in a secure upland contain- ment facility. Current Status; In September 1980, Congress passed an amendment to the Clean Water Act (CWA) under Title 1, Section 116(a) and (b), entitled, "The Hudson River PCB Reclamation Demonstration Project." Under this legislation, construction grant funds up to $20,000,000 could be authorized by the EPA Administrator if he determined that funds were not first available under Section 116 or 311 of the CWA or from the then-proposed CERCLA. Congress authorized EPA to make grants to the NYSDEC in order to carry out the intent of the Act. The funding authorization was due to expire on September 30, 1983, but has since been extended (See Attachment 1). The Hudson River Sloop Clearwater and other environmental groups and New York State brought suit to compel EPA to award the balance of $20 million under Section 116 of the Clean Water Act for the Hudson River Reclamation Demonstration Project. The parties agreed to a court order extending the September 30, 1983, expiration date of Section 116 funding. In March, 1984, EPA released funds provided under an earlier grant for the hot spots verification. On May 10, 1984, EPA entered into a settlement agreement with the plaintiffs. Under the terms of the agreement, EPA will make a grant to New York of approximately $18 million for dredging and disposal of PCBs if the State obtains an acceptable disposal site with all necessary State and federal permits within three years. The lawsuits were dismissed. As a result of federal involvement and in accordance with the National Environmental Policy Act (NEPA) and requirements in Section 116, EPA Region II, on May 8, 1981, issued a Draft Environ- mental Impact Statement (EIS) on the Hudson River PCB problem. This was followed by a Supplemental Draft EIS on August 18, 1981. After review of the Final EIS (issued October 8, 1982), ------- - 3 - the NEPA process was concluded on December 30, 1982, with a Record of Decision in which the EPA Administrator determined that funds for addressing this problem were available under CERCLA and that the problem rated sufficiently high to be considered for inclusion on the National Priorities List (NPL). A Remedial Action Master Plan (RAMP) was initiated in May 1983 to evaluate all available information and assess feasible remedial options consistent with the National Contingency Plan. Before the RAMP was completed, the Hudson River PCBs Site was placed on the EPA's proposed NPL and, as a result, became eligible for CERCLA funding. The RAMP was subsequently changed to a feasibility study since the elements necessary in such a study were already incorporated within the RAMP document. A draft Feasibility Study report was completed in September 1983 and became available to the public for a thirty (30) day- review period starting October 7, 1983. Due to requests received at the public meeting held in Albany, New York on November 3, 1983, the comment period was extended to November 30. The majority of the information used in this study was generated as a result of a 1977 sampling effort conducted by the NYSDEC, This sampling program established the hot spot locations. A limited amount of sampling was performed at selected hot spots'" in August 1983, by EPA. The 1983 data,-when compared with the 1977 survey results, suggested that some hot spots may have shifted, while others stayed in place. This summer NYSDEC staff have conducted an intensive sediment survey in the Thompson Island Pool. The purpose of the survey is to confirm the presence of PCB hot spots in the Upper Hudson River sediment and to identify their boundaries for dredging design purposes. In addition to the survey, the CWA Section 116 grant will fund the United States Geological Service's annual water monitoring, development of a DEC caged fish monitoring program, and DOH macroinvertibrate studies in the Upper Hudson River. Grant funds will also pay for a sediment erodibility study, a PCB transport study, and a PCB volatilization study. Enforcement; On May 5, 1983, EPA met with G.E. representatives to discuss the Agency's intentions of listing the Hudson River PCB Site on the NPL and to pursue negotiations with the company. The site was subsequently listed on the September 8, 1983 proposed NPL update. On October 27, 1983, EPA issued a Notice Letter to G.E. as a responsible and liable party. This letter notified G.E. of EPA's • intentions to conduct a predesign sampling program and implement the remedial alternatives unless the company agreed to do so itself. ------- - 4 - G.E. responded to this letter by calling EPA's notice premature and unjustified. First. G.E. objected to the fact that EPA issued a notice letter for a site that is not on the NPL; and second, the company did not recognize a threat caused by the site to human health or the environment. EPA has responded to G.E.'s letter by stating that remedial planning activities can be undertaken for a site on__tjie__p_ropjosed list. EPA may issue an 6rder to the company for remedial design and cleanup. EPA also discovered that the Niagara Mohawk Power Corporation may also be a site owner and responsible party. A notice letter was issued on February 29, 1984, to Niagara Mohawk, and an order will be issued if it is determined that the company is a responsible party. Niagara Mohawk, which utilizes the Hudson River for hydroelectric power, received a permit to remove the dam located in Fort Edwards, which eventually resulted in the formation of the hot spots downstream. Alternative Evaluation: The major objective of the feasibility study was to evaluate remedial alternatives using a cost-effective approach consistent with the goals and objectives of CERCLA. A cost-effective remedial alternative is defined in the National Contingency Plan (NCP) (40 CFR 300.68(j) as "the lowest cost alternative that is techno- logically feasible and reliable and which effectively mitigates " and minimizes damage tQ and provides adequate protection of public health, welfare, or environment." The NCP outlines procedures and criteria to be used in selecting the most cost-effective alternative. The first step is to evaluate public health and environmental effects and welfare concerns associated with the problem. Criteria to be considered are outlined in Section 300.68(e) of the NCP and include such factors as actual or potential direct contact with hazardous material, degree of contamination of drinking water, and extent of isolation and/or migration of the contaminant. The next step is to develop a limited list of possible remedial actions which could be used. The no-remedial-action alternative must be included on the list. Included were alter- natives previously examined in the EIS and additional actions such as treatment of public water supplies. A number of new PCB treatment and destruction technologies were also reviewed to ensure that all reasonable alternatives were considered. The third step in the process is to provide an initial screen- ing of remaining alternatives. The costs, possible adverse effects, relative effectiveness in minimizing threats, and reliability of the methods are reviewed. This analysis requires a more detailed estimation of costs and engineering implementation and a closer assessment of the ability of alternatives to minimize or mitigate threats. In this study, the detailed analysis was aided by a cost-effectiveness matrix which was developed by independent consultants under the direction of EPA. ------- - 5 - Alternatives were broken down into two specific categories for evaluation. These were: o River sediment alternatives o Remnant deposit alternatives A list of potential feasible alternatives has been assembled in Table 3, and associated costs have been provided. Based on the analysis described above, the various categories of alternatives were evaluated, and the following conclusions were .reached: River Sediments As outlined in the previous section, an alternative evalua- tion was initiated to determine which technologies would provide adequate protection to public health and the environment from the major contaminant pathways. The primary pathways that threaten public health are the ingestion of contaminated fish and the contaminat-ion of municipal drinking water systems. The spread of contamination to both of these pathways has not been fully quantified, since the PCBs are concentrated in the River sediment and the mechanisms of transport from the sediment to the water column and/or fish are poorly understood. Although studies of the river system are continuing, sufficient data to support a no-action alternative as the permanent recommended alternative are not available at this time. Therefore, Numerous alternatives were assembled which potentially addressed the river sediment problem. Included in this list were various new technology options for in-river detoxification such as degradation by ultraviolet light, ozoni- zation, chemical treatment, bioharvesting and activated carbon adsorption. In addition, in-river containment methods were analyzed for both shallow 'deposit locations and areas of high deposition. While new technologies were explored in detail within the study, the majority of these options, though appealing, were dropped from consideration due to limited testing or lack of availability. These new technologies may be proven in the near future under more controlled circumstances (i.e., the OMC site) or under other types of study efforts (i.e., the CWA Section 116 demonstration project). Upon the successful completion of these types of projects, the recommendations presented in this document may very well need to undergo reevaluation and possible revision. An evaluation of the treatment technologies indicated that although all of the technologies proved to be useful—or potentially so—in removing PCBs from oils, not all of the treatment methods could be used in connection with PCB- contaminated sediments. Some of the treatment technologies were found to be applicable for sediment decontamination, ------- - 6 - but only two processes, KOHPEG and NaPEG, were found to be potentially applicable as an in-situ solution. For the other treatments, the sediments must first be exposed (by dredging or by river level reduction) and treated after dewatering. Unfortunately, even the KOHPEG and NaPEG processes are still in the early stages of development, with little information being available on their'environmental effects and costs. For this reason, these alternatives were dropped from further consid- eration at this time. Such new technologies listed above may prove not only reliable but practical at some point in the future, and might be available to address PCB problems which may exist in the Hudson River at that time. Ip-river containment was evaluated in relation to other options available. It was determined that the initial costs associated with containment were comparable to a dredging option, however, the maintenance costs would be perpetual and, therefore, restrict!vely high. Also, the capping of contaminated deposits in a river "system offers numerous technical and maintenance problems. In addition, it is likely that even if technical problems can be resolved, installation of an artificial cover could result" in a short-term disturbance(by less-contaminated sediments) of the contaminated sediments and their existing natural cover. In turn, this may substantially increase the contamination in the water column for some time thereafter. Finally, although an artificial cover could in theory decrease the overall long-term release of PCBs into the Hudson River environment, the marginal increase in protection (as compared to the natural sediment cover which now exists) will be considerably outweighed by the very high cost of such an action. For these reasons, this alternative was removed from further consideration. EPA also evaluated the option of bank to bank dredging of the entire river. This alternative would remove the bulk of the PCB's on the upper river and therefore would be most effective in reducing the long-term public health and environmental threats from PCB exposure (although significant amounts of PCB's would be released into the water column in the short term). However, bank to bank dredging could be environmentally devastating to the river ecosystem and cannot be considered to adequately protect the environment. In addition, even if the negative impacts could be eliminated, disposal of this quantity of contaminated sediments would require an impractically large containment facility. Finally, the cost of the bank to bank dredging alternative, given the level of risk presented even if the Agency takes no action, would appear to be excessive given the need to respond to other sites which may present threats to public health, welfare, and the environment. ------- - 7 - EPA also evaluated two additional options which involved dredging a number of "hot spots" in the upper river basin. The full scale hot spot alternative would involve the dredging of 40 hot spots, and the more limited option would address 20 hot spots. These programs would remove an estimated 28-46% of the PCBs in upper river sediments, and an estimated 18-29% of the PCBs in the entire river. PCBs are ubiquitous in low concentrations throughout the river system, and the hot spot program would not address these low concentration areas. Furthermore, it is not clear that elimination of 28-46% of the PCBs in the river system would result in an equivalent decrease in the total amount of PCBs released from river sediments into the water column. It is possible that the rates of release in the environment are related to the exposed contaminated surface area of the river bed, and the hot spots constitute only about 8% of the affected area in the upper Hudson River Basin. Modeling indicates that removal of the hot spots would have some positive effect on the river environment. One model produced an estimate that for the 40 hot spot dredging alternative it would take approximatly 46 years for PCBs in the Upper Hudson River to be fully depleted. Under the no action option for the river sediments, this model indicates that the PCBs in the upper river would be fully depleted in approximately 64 years (these time periods should only be considered indicative of the relative benefits of the no-action and hot spot options, since there are considerable uncertainties in the models). Furthermore, the times given refer to total depletion of PCBs, and it is likely that some level short of total depletion can be considered to provide adequate protection of public health and the environment. For example, although individual fish still may be highly contaminated with PCBs, the average level of contamination has declined below the FDA limit, and this decrease is expected to continue. The above figures on the amount of PCBs which would be removed by hot spot dredging assume that a very high percentage of the PCBs in the hot spot areas would be controlled. However, the technology and methodology of this type of dredging in a dynamic, riverine environment is unproven and uncertain. Dredging activities by their nature tend to result in some degree of disturbance of the highly contaminated sediments, and thus result in some short-term problems, in the form of elevated PCB concent- rations in the water and air, as well as increased fish contamin- ation. Because the technology for reducing the disturbance of the sediment or controlling the spreading of the suspended materials is unproven in this type of a situation, it is difficult to estimate reliably the amount of the contamination which will be recovered or, on the other hand, the level of short-term damage which may result from releasing the PCB materials into the water column. Therefore, it is difficult to conclude at this time that the technology can be considered feasible or reliable. ------- - 8 - The estimated.cost of the limited and full-scale hot spot dredging alternatives is $34,000,000 and $55,000,000 respectively, assuming that a secure containment area could be constructed in the vicinity of the dredging site. However, the likelihood of such a 'site being available in the near future is highly question- able. Disposal of the wastes at the closest currently available site would increase the cost by as much as $200 million. (See PCB Disposal Alternatives discussion, below). Finally, EPA evaluated the no-action alternative. This alternative could result in leaving 500 thousand pounds of PCBs in the river system . Natural on-going sediment transport mechanisms within the river have covered many of the PCB contam- inated areas (hot and cold spots) with a less contaminated sediment layer, which significantly reduces the migration of PCBs in the water column and exposure to aquatic life. Based on reviews of current data, the average level of contamination of -Hudson River fish has declined below the FDA limit of 5 ppm although highly- contaminated individual fish are still found in both the Upper and Lower Hudson. Consumers of fish are warned of exposure by NYSDEC restrictions that have been in effect since 1976. While the fish consumption limitation suggested by the ban certainly is not a solution to the problem, it does offer some level of protection. It is important to note that detectable levels of dioxin, dibenzofurans, mercury and chlordane (from known and unknown sources) have also been identi- fied in Hudson River fish, and that even if PCBs decrease to an acceptable level, the fishing bans would continue on the basis of these other types of contamination. The enforcement of the fishing bans and the continued monitoring of the contamination should reduce the threat to consumers while the fish population continues its natural recovery during the interim evaluation period. It is projected that the natural assimilative capacity of the river will continue the downward trend in the levels of PCBs found in the river. Concerns have also been raised regarding the effect of the no-action alternative on future ocean disposal of the dredged sediments generated during periodic river maintenance operation. Past conclusions about the problems with ocean disposal of dredged sediments may be misleading. The Draft Environmental Impact Statement indicated that, if certain unusual conditions were to occur, the PCB concentration of harbor sediments would continue to increase to a level above disposal limits and thereby restrict ocean disposal. This projection assumed that all of the PCBs in the Upper Hudson would reach the harbor in 64 years and that the dredging rate would remove at least a constant 4000 pounds of PCB per year (assuming sediment concentrations would either remain the same or increase). ------- - 9 - It is now recognized that recently deposited harbor sediments are lower in PCB content than older sediments. Since dredging generally removes only the most recently deposited material, ocean disposal of dredged material should not be adversely impacted. If present conditions continue, the amount of PCB passing into the estuary will continue to decrease with time. Also, it is expected that, at the wqrst, the PCB concentration of previously deposited sediments will remain at current levels (about 3 ppm) and the level of PCBs in fresh dredge spoils will decrease. Furthermore, it has been shown by the "Final Environmental Impact Statement on Federal Channel Maintenance Dredging" that dredging plans for the next 10 years will not likely involve sediments of greater than 1 ppm PCB concentration, and that maintenance dredging is not expected to create significant environmental impacts. In conclusion, while the no-action alternative cannot be considered to provide fully adequate protection to human health and the environment (due to the fact that several hundred thousand pounds of PCBs would remain in the river subject to only partial natural containment), both the modeling and sampling data collected to date indicate a decreasing threat to public health and the .environment. The lack of sufficient data to establish the fate and transport of PCBs in the Hudson River prevents the Agency from making a final determination of no-action. Additional environmental data collection will continue during the interim evaluation period on feasible and reliable alternatives. The most feasible and reliable alternatives assessed by EPA (limited and full scale hot spot dredging) would be likely to decrease the level of risk somewhat. However, as is mentioned above, the actual reliability and'effectiveness of current dredging techno- logies in this particular situation is subject to considerable uncertainty. For this reason the no-action alternative is recommended at this time. This decision may be reassessed in the future if, during the interim evaluation period, the reli- ability and applicability of in-situ or other treatment methods is demonstrated, or if techniques for dredging of contaminated sediment from an environment such as this one are further developed. For example, dredging on a more limited scale may be conducted in the Hudson under the authority of §116 of the Clean Water Act; techniques developed for dredging operations under more favorable conditions at other Superfund sites may be applicable to dredging in this situation. However, even if hot-spot dredging technologies were more reliable, the estimated high cost of dredging and disposal might rule these out based on Fund-balancing considerations, especially given the moderate degree of risk reduction which may be achievable. To protect area residents, the proposed action also includes a detailed evaluation of the Town of Waterford's water treatment facilities. This would include a sampling program and a subse- quent analysis of the treatment operation. The decision for providing upgraded or alternative facilities could then be made. ------- - 10 - Even though existing data show little problem at Waterford. there is a possibility that a threat could arise. The cost of this evaluation is low ($120,000), and is justified to ensure protection of the public. Treated drinking water from the Waterford supply system rarely exceeds 0.1 ppb of PCBs according to United States Geolog- ical Survey (USGS) studies. Based on results of 35 samples (collected by N.Y. State), the PCB concentration of Waterford drinking water averages 0.06 ppb. No study of Waterford drinking water has ever found PCB concentrations in excess of 1 ppb, which is the maximum allowable exposure promulgated by the New York State Department of Health (NYSDOH). However, analysis of river water quality at Waterford indicates incidents where PCB concentrations have exceeded 1 ppb, therefore, generating some concern and thus a more thorough evaluation is needed. The USGS has taken samples of the water before and after treatment in the mid-1970's. Analysis of these historical data show that concentrations of PCBs in the river water are greatest during high flows and during low flows. Consistent with this, water supplies at Waterford should be sampled during the spring, when flows are highest and during August or September when flows are at a low. The water should be sampled before and after treatment. The sampling results will allow evaluation of the effectiveness-' of the treatment facilities and show whether upgrading is required. Remnant Sites An alternative evaluation was performed consistent with the procedures outlined previously. fncluded in the list of alter- natives was an array of options that were initially reviewed in the EIS. Of primary concern was the potential for direct contact by the public with the PCB contained within the remnant sites. This was found to occur via two pathways, one being direct physical contact by being on the site and the other through an air vector whereby PCBs migrating either through adherence to dust particles or volatilization would reach bordering communities. A secondary concern was the continuous discharge of PCBs from the remnant sites into the river. Based on the alternative assessment, three options were determined to mitigate adequately the pathways for human exposure through direct contact and volatilization, although the degree of effectiveness differed among them. These three options also either eliminated or limited the migration of PCB contamination into the river. The three alternatives selected for further analysis included; o Complete removal of the remnant sites, o Partial removal of the remnant sites, and o In-place containment ------- -li- lt was found that complete removal of the remnant sites would provide the most effective option for addressing PCBs and the associated pathways of exposure. This option would provide for the elimination of the direct contact pathway which is the major health concern, and would eliminate leaching of PCBs into the river from these sites. In addition, this action would be consistent with current TSCA requirements to provide secure facilities for PCB waste. While TSCA PCB regulations would not require that this contamination be removed, since the creation of the remnant sites preceded the enactment of TSCA, the TSCA technical standards of the regulation would generally call for PCBs to be disposed of in approved landfills and not located in floodplain areas. While this option would eliminate the long-term impact associated with the PCBs, there may be some adverse short-term impacts on public health. Any large-scale excavation action will result in an increase in a PCB release to the air (This is documented by past dredging operations where air concentrations of PCBs rose from less than 1 ug/m^ to 9 ug/m^ during the removal of remnant site 3A). In addition, a large number of truck trips (40,000) would traverse residential areas, creating a potential health hazard and disrupting normal activity. Erosion and resuspension of PCBs into the river would also increase during the removal operations. A removal alternative would be most effective in eliminating any possibility of future PCB exposure from the remnant sites. An evaluation of the cost associated with such an action indicates that initial capital cost would be in excess of $12,000,000, based upon the availability of a secure landfill within the study area. As mentioned previously, the possibility of a local site being available is remote. A rough estimate of the additional expense that would be required to transport and dispose this material at a secure site (the closest being Niagara Falls) indicates that $50,000,000 would be needed. The second option is the excavation and off-site disposal of the portions of the remnant sites contaminated with greater than 50 ppm PCBs, and the in-place containment of the remaining PCB-contaminated portions of the site. This option, like the other two options, would eliminate the risk of direct contact with PCB contamination in the remnant deposits (assuming the cap is properly maintained) and by decreasing the amount and concen- trations of PCBs contained would substantially reduce the amount of PCBs migrating into the Hudson River via ground water (as compared to alternative 3, described below), although unlike alternative 1 it would not completely eliminate such discharges. However, the second option poses the same problems as the total removal option, in that it would require large scale excavation which has the potential of releasing increased amounts of PCBs into the air over a short period of time. Limited removal would be less expensive (approximately $9,000,000) than alternative 1, ------- - 12 - but it would still be substantially more expensive than alternative 3, especially in the absence of a secure disposal area near the sites. The third option assessed was in-place containment of the PCB-contaminated remnants. This option was recommended over excavation and off-^site disposal in the EIS prepared for these sites. The originally proposed alternative envisioned the complete isolation of the remnant deposits by construction of impermeable walls or barriers and installation of clay caps. As explained below, further analysis indicates that complete isolation is neither feasible nor practical at these sites; however, the amount of PCBs which may be discharged to the river is relatively low, especially in the context of existing levels of contamination in the river. The remnant sites are located on the floodplain of the river. Some of the contaminated sediments were found to be up to 15 feet deep. Thus, it would be impossible to prevent the ground water, which at this point is directly related to the river level, from entering the contaminated sediments from the bottom (through the soil). Isolation of the remnant sites hydrogeologically would be very difficult without some form of bottom sealing using impermeable materials. Bottom sealing has only been looked at on a lab scale, and has not been demonstrated to be technolog- ically achievable at this time. Since the remnant sites could not be totally isolated from ground water, there is no point in constructing impermeable barriers around them, nor is there any point in installing a clay cap. A soil cover using 18" of subsoil placed in 6" lifts and a final 6" layer of topsoil would adequately achieve the primary objective of eliminating direct public contact with the contaminated materials while also substantially reducing infil- tration (80 percent compared to 90 percent for a clay cap). In addition, a rip/rap stabilization system upgraded above the 100 year flood level will assure the integrity of the sites. (See Addendum 1). Finally, the sites will be fenced and posted to prevent public access. There is, however, the potential that without proper maintenance and monitoring of these sites, PCBs may become exposed and present a health risk. Under the third option, the remnant deposits would continue to provide a source of PCB migration, through ground water, into the river system. However, while levels of PCBs migrating from the site have never been measured, it is believed that the bulk of the PCBs are locked up in the remnant materials, and that the discharges into the river are at relatively .low levels. In light of existing levels of PCB contamination in the river system, it is believed that such discharges are not particularly significant. ------- - 13 - Each of the options assessed would be effective in mitiga- ting or eliminating the threats to human health from direct contact and volatilization. In-place containment would address this concern for a cost of $2.3 million, substantially less than the other two options. Options 1 and 2 would also eliminate or reduce the migration of PCBs into the river system through ground water. However, both excavation options pose a similar risk of a short-term increase in the release of PCBs, and both are sub- stantially more expensive than option 3. Given this substantial additional expense, it is important to assess the utility of eliminating this small source of PCB release. But this is difficult to determine, pending an ultimate decision on whether and how the contaminated sediments will be addressed. Therefore, because in-place containment is the least expensive option that effectively mitigates the direct contact threat and because the merits of excavation cannot be adequately assessed based on current information, in-place containment is the recommended remedial option for the remnant sites at this time. The appro- priateness of further remedial action for these sites will be reexamined if EPA decides at a later date to take additional action with respect to sediments in the river. PCB Disposal Alternatives: In order to assess the costs of each of the dredging/remnant excavation projects discussed above, an evaluation was performed which reviewed available PCB disposal options. These included a range of options from placement in a secure landfill to detoxifi- cation/destruction techniques. While the new technological options were appealing, the limited historical data available were sufficient to conclude that these alternatives would be unreliable at this time, but quite promising in the future. An analysis of remaining alternatives was then undertaken with the following two assumptions: o for all options, dredging of PCB hot spot sediments/remnant sites would be performed, and, o a site would be provided by N.Y. State within the study area that would by acceptable as a secure landfill for the PCBs. The most effective disposal option available was determined to be incineration since it would provide almost complete destruc- tion of the PCBs. However, the capital costs associated with constructing a multi-incinerator system that would have the capacity to handle the massive amounts of PCB sediments would be quite large, approximately $250,000,000. A wet air oxidation process which could be applied to the removed sediment was also found to be effective, but would require extensive land area during operation. The capital cost for this option would be higher than incineration. ------- - 14 - While the two alternatives discussed above were found to be the most effective in containing and/or removing the harmful aspects of PCBs, their costs were a limiting factor. EPA also evaluated the disposal of the PCB sediment in a secure landfill, which satisfied the PCB regulations under TSCA. This facility would be located within the study area and would be effective in providing an adequate level of protection for the public and the environment. The costs associated with such an option would be approximately $20,000,000 and therefore would represent the cost-effective alternative. Note, these estimates assume that a containment site would be available within the study area. Based on recent events the likelihood of this occurring in the immediate future is remote. With this in mind, a rough assessment of disposal costs at a privately owned secure facility (the closest being CECOS in Niagara Falls, N.Y.) indicates that, for 40 hot spots or approx- imately 1,450,000 cu. yd. of material, costs in excess of $120,000,000 could be anticipated. Transportation costs are not included and would add an additional $90,000,000 to this figure. Community Relations; In October of 1982, EPA issued a Final Environmental Impact Statement (EIS) on the Hudson River Demonstration Project. In the December 1982 Record of Decision (ROD), EPA found that the project should be considered for funding under CERCLA (Superfund). See Attachment 2. Under Superfund, the NUS Corporation was requested to prepare a Remedial Action Master Plan (RAMP). During the development of the RAMP, it was determined that the document contained all the elements to be considered a feasibility study and it was renamed such in order to accelerate the decision process on remediation at the site. The draft feasibility study was the subject of a public meeting held in Albany in November 3, 1983 (Attachment 3). As a result of comments at the meeting, the public commment period (originally scheduled to run 30 days and end on November 7, 1983) was extended through November 30, 1983. Numerous comments were received from a broad range of public and private concerns. Response to these commments is the subject of a responsiveness summary prepared by EPA and its consultant, NUS Corporation. ------- - 15 - Consistency with Other Environmental Laws; The recommended alternative for the remnant sites has been reviewed for consistency with regulations under TSCA governing the handling and disposal of PCBs. The TSCA regulations do not require that PCBs disposed^ (including PCB-contaminated soil) in a landfill before February, *1978, be removed. However, the rules provide that if PCB-contaminated soil is disposed, or if PCB contamination is removed for disposal after that date, it must be disposed of either by incineration or in a chemical waste landfill which complies with the TSCA PCB regulations. If these regulations were legally applicable to the remnant deposits, containment using the methods described above would not meet those standards. For example, the containment area is not located in low permeability soil and does not include a synthetic liner; is not sufficently above the ground water table, and is located in a floodplain area. Full consistency with these TSCA standards is not being achieved because in-place containment is intended as an interim remedy to address the direct contact and volatilization threat posed by the sites. The remedy is not intended to eliminate the low levels of release of PCBs into the Hudson River. Cost; The following figures represent an estimate of the costs associated with the proposed actions. It has been the decision of the NYSDEC to take the lead on this project. The site has been classified as a 90 percent federal and 10 percent State cost-sharing site for remedial implementation activities. Activi cy Capital Cost Design of remnant sites containment (RD) $200,000 Implementation of remnant containment (RA) 2,230,000 Waterford water supply evaluation 120,000 State administration/management (12%) 310,000 ($278,000 for construction) TOTAL $2,950,000 ------- - 16 - Federal Share State Share 90% (RA) $2,338,200 • • $ 259,800 100% (RD) 352,000 e Total $2,690,200 $259,800 $2 ,950,000 The above figures for remnant containment are based upon covering all sites with surface dimensions estimated from existing data. Actual pre-design evaluation, however, may result in a containment area somewhat smaller due to site erosion or reevaluation of PCS levels. Schedule: Proposed schedules for the recommended activities have been prepared (Figures 4 and 5). ------- TABLE 3 REMEDIAL ALTERNATIVES AND COST COMPARISONS HUDSON RIVER PCB SHE. NEW YORK Remedial Alternative 1. Delon. of Sediments with KOHPEO 2. Wet air oxidation of sediments 3. Incineration of sediments 4. Secure landfill disposal of sediments 5. Dredging of 40 hot spots 6. Reduced scale dredging 7. No remedial action, water supply not treated 8. No remedial action, water supply treated B. Total removal of all remnant deposits 10. Partial removal of remnant deposits 11. Restricted access to remnent deposits 12. In-place containment of remnant deposits 13. tn-sltu detoxification of remnant deposits 14. No action on f 1, 2. &4/restrlcl access to f 3 ft 5 IS. Partial removal/contaminant of remnant deposits IB. Pertlal removal/restricted access of remnant deposits 17. Partial containment/restricted access to remnant deposlta 18. Partial contamment/tn-sltu detoxification of remnant deposits 1B. Partial removal/ln-sltu detoxification of remnant deposits 20. Partial detoxification/restricted access of remnant deposits Capital Costs $289.877.000 $109.340.000 $249.787.000 IS.203.000 54.987.000 34.048.000 120.000* 114.000 12.894.000 6.917.000 372.000 2.324.000 66.696.000 154.000 9.010.000 7.144.000 $ 1.053.000 $ 38.878.000 $ 42.822.000 $ 38.853.000 OB.M Costs B B B 1.887.BOO S.321.000 5.321.000 3.434.BOB 3.617.BOO 1.887.000 3.011.000 1.124.000 1.124.000 B 1.124.BOO 3.Oil.BOB 3.011.000 $ 1.124,000 $ 1.124.000 $ 1.887,000 $ 1.124.BOB Total Costs $289.877.BOO $109.340.BOO $249.787.000 17.090.BOO 60.308.000 39.369.000 3.434.000 3.731.000 14.781.000 9.928.000 1.498.000 3.406.000 66.696.000 1.278.000 12.021.000 10.155.000 $ 2.177.000 $ 40.002:000 $ 44.509.000 $ 37.977.000 •Includes Proposed Treatablllty Study ------- -2- The draft feasibility study will be available for a three . public ceMMnt period as toon as the finishing touches are placid on the document. We expect public release before October 7, 1983 After analysis of public comments, a final remedy under CERCLA be selected for design and impl•mutation. it appears that CERCLA funds nay not be available for the dredging project, I have decided to consider an application under section 116 for a PCB demonstration project. The State ojt, New York should prepare an application sufficient to eeec all of the statutory requirements set out in section 116. :T*o of the requirements which are of particular concern to ne art this- point are the availability of a secure landfill site, and better jJata . defining the location of the significant bottom sediment areas. As you know the State of New York was recently directed to revoke the State permits for the secure landfill site previously selected. Further, recent EPA sampling of the PCB contaminated sediments in August 1983 indicates the location of the areas may have shifted since the last sampling was done in 1977. 1 am willing to consider a PCB dredging project for funding when these two natters are resolved. The potential problem of the authority and funds available.. under section 116 expiring on September 30, 1983^4was alleviated on September 23, 1983 when a consent order was issued in the lawsuits where the Agency's prior decisions to proceed under CCftCLA on the PCB project are being challenged. In those suits, brought by several environmental groups* Congressman Richard Ottinger and the State of New York, I have agreed to a court order deferring the expiration date of the authority to expend funds under section 116(b). This order should give us the opportunity to insure that the intent of Congress is carried out. The Agency shares your concern that this matter be acted on as soon as possible. We are ready to proceed promptly toward implementing the appropriate measure to solve problems caused by PCBs in the Hudson River* ^.~. Sincerely y&ors, William D. Ruckelshaus ------- [ATTACHMENT 1 * UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ' WASHINGTON. D.C' 20460 r* 9 Because of the continued interest in the PCB reclamation project in the Hudson River, I am writing to advise you of toy resent intentions concerning that project. In our July 26, 1983 meeting and my subsequent letter to iou, I indicated that EPA was conducting an evaluation of possible Iternative remedial actions which could he undertaken to mitigate he PCB contamination problem in the Hudson Kiver. The Agency has eceived the preliminary results of its feesibi^ty study which ncoroorated the data developed in our October 1982 Envircnmuntal mpact Statement (EIS) and an additional analysis of cost-efiecti :lternatives. The draft feasibility study considered 36 alternative Cleanup plans including a number of new PCB treatment and destruction technologies. All reasonable alternatives were considered.* The recommendations in the draft study indicate that the only cost-effective actions that should be considered for funding under the Comprehensive Environmental Respcna*, Compen- sation and Liability Act (CERCLA) are (1) the containment of exposed deposits of polychlorinated biphenyls (fCBs) at five contamined areas along the shoreline of the Hudson River and (2) the evaluation of drinking water supplies atwaterford, New York to determine if PCB contamination poses any potential threat to the public. Preliminary estimates are that the shoreline project would cost approximately SI.8 million. The study also concluded that the dredging of bottom sediments, whose PCB concentration is greater than 50 parts per million, is not cost-effective because: (1) the lack of a defined threat to public health, and (2) the difficulty in showing that significant environmental and public health benefits would result. ------- TABL£ 2 Estimated Mass of PCB in the Hudson River Basin Associated with Ganeral Electric Plants Near Fort Edward, New York UPPER HUDSON RIVER BASIN Remnant Deposits 46,820 - 108,600 pounds1 Thompson Island Pool Sediments2 Hot Spots 97,700 - 105.800 Cold Areas 22,000-30,900 Remaining Upper Hudson Pools Hot Spots 60,600-64,100 Cold Areas 101,400 - 146,400 Subtotal, Upper Hudson River Sediments Only Hot Spots 158.300 - 169,900 Cold Areas 123.400 - 177.300 281,700 - 347.200 Dredge Spoils 103,455 - 160,000 Dumps 528,000 - 745,000 Subtotal, Upper Hudson Basin Only 959.975 - 1.360.800 LOWER HUDSON RIVER BASIN Sediments 169,000 - 200,000 Dredged 86,000 Washed out to sea 200,000 TOTAL PCB 1.414,975 - 1 .846.800 1 Remnant deposit totals do not include estimates for area 3A. 2 Thompson Island Pool totals include estimates for sediments above Lock 7. Sources: Bopp et al. 1978 • Hetling et al. April 1978 Tofflemire and Quinn 1979 Malcolm Pirnie 1980 2-2 ------- TABLE 1 PCS CONTAMINATION IN REMNANT DEPOSITS Remnant Area 1 2 3 3a 4 4a 5 Total Area (acres) 4.0 8.0 13.3 6.0 12.0 8.5 55 .'8 Avg. PCB Cbnctntration (pom) 20 5 65 1000 25 40 250 Contaminated Depth (ft) 2 5 8 1 2 3 8 Contaminated Volume (vd3) 12,900 64,530 160.925 9.680 38,720 41.140 31.630 359,525 Less Area 3a Remaining Source: (Tofflemire, 1980). PCB Mass m 450 570 18,550 17,000 1700 2900 22.650 63,820 17.000 46.820 4-9 ------- WMNANT «MA 4 •OlOO-v/ NEMNANT MtA I 10*00 SARATOGA COUNTt COVERED n THE IOO VEAN FLOOD LIMIT OF IOO YEAR FLOOD STAGE PLAN VIEW, REMNANT DEPOSITS HUDSON RIVER PCB FIGURE IMUS CORPORATiaN A Halliburton Company ------- c. (Source-Malcolm Pirnle Sept. 1980) PROJECT AREA LOWER HUDSON HUDSON RIVER PCB SITE, HUD SCALE' l"= 16 MILES IVER. NY FIGURE 2- rs ------- ALBANY CO ALBANY MO RENSSELAER CO. (Soured - Malcolm Pirni«, Sept. I960) WARREN CO. WASHINGTON CO. FORf EDWARD J:/X GLENS \--/ FALLS HUDSON FALLS PROJECT AREA UPPER HUDSON HUDSON RIVER PCB SITE. HUDSON RIVER. NY NOT TO SCALE FIGURE | IMUS A Halliburton Company ------- -1- ADDENDUM 1 Hudson River PCBs Site New York FLOOD PLAIN MANAGEMENT ASSESSMENT • • I. Purpose The purpose of this addendum is to: 1. Review Executive Order No. 11988, May 24, 1977, 42 F.R. 26951 entitled Floodplain Management; 2. Review applicable status referred to in the Executive Order as required; 3. Review the proposed remnant, site contaminment option as it relates to the floodplain of the Hudson River; 4. Summarize the review and describe any technical requirements necessary to comply with (1) and (2) above. II. Introduction A feasibility study was prepared by NUS Corporation, EPA's consultant, which evaluated alternatives to remediate the PCB contamination at five (5) remnant sites located in the Upper Hudson River floodplain. Thuse remnant sites were formed when the Fort Edward Dam was removed in 1973 leaving more than 1.5 million cubic yards of contaminated sediments in five discrete deposits exposed along the edges of the river in a 1.5 mile stretch upstream of Fort Edward. The locations of these remnant deposits are illustrated in Fiqure I. A large percentage of the PCBs have been scoured and transported downstream. In addition, some have been removed through prior dredging. Approximately 10 percent of the total PCBs remain. The remnant deposits contain high amounts of sawdust, wood chips, and other debris remaining from a once thriving lumber industry. The most highly contaminated sediments were generally found in the top few inches of sample cores? however, significant contamination extended up to 10 feet below the surface. PCB levels ranged from 5620 ppm at the surface of a core from site 3a to less than 3 ppm, which was commonly .found a few inches deep in many samples. PCB concentrations tended to increase with distance from the edge of the present below bank. This trend is characteristic of the river below the remnant deposits and is related to velocity distributions and sediment characterisitics as will be discussed later. ------- -2- The remanant deposits were subjected to a number of remedial activities between 1974 and 1978, the most significant of which was the excavation and containment of remnant area 3a. The unstable banks of areas 3 and 5 were graded and stabilized with stone riprap and these areas, along with area 2 were revegetated. An aerial Inspection in 1983, however, revealed that the plantings had not taken well. Remnant deposit 1, which is an island, had not been subjected to any remedial action. The aerial inspection in 1983 showed it to be much smaller than before. Ninety percent of the time, the river surface elevation is at or below the lower boundary of significant PCB contamination within the remnant deposits (Malcolm Pirnie, Inc., 1978). Thus, bank scour during periods of high flow is the principal mechanism responsible for the transfer of PCBs to the lower reaches. Infiltrating rain water and runoff, as well as groundwater movement, carry some desorbed PCBs to the river; however, this contribution is insignificant compared to the PCB load passing Rogers Island. Remnant deposit saturation during floods would not contribute significant amounts of PCBs to the river since the hydraulic gradient would slope away from the river during these periods and desorbed PCBs would be carried inland where they would be attenuated by soil particles. Malcolm Pirnie, Inc., (1978) estimated that approximately 8600 pounds of PCB per year were lost to the river from the remnant deposits before remedial activities were implemented. Tofflemire and Quinn (1979) suggested that after remediation, the unstable bank areas of remnant deposit 4 presented the greatest potential for future erosion losses. The most highly contaminated desposits, areas 3 and 5, are not likely to erode because they are adequately protected against flows substantially higher that the average annual flood. Figures II through VI depict typical cross sections at the remnant deposits and relate contaminated materials and remedial construction features to river stages. ------- -3- Inscribed on these figures are the values for the average annual and 100 year flood elevations. The following table illustrates the current situation. It is important to note that the figures are based on data accumulated in 1977 and since then erosion and runoff may have altered the dimensions of the remnant areas. Elevation (feet above mean sea level) Remnant Site 1 2 3* 4* 5* 1977 Site 134 >137 >132 >132 >130 Average Annual Flood 133 ,133 130 133 127 100 Year Flood 137 138 134 133 130 *Site partially riprapped These sites are basically in pool type areas of the Hudson River where flow vectors would be less than in the main channel of the river. Ill. Proposed Site Remedial Action The selected remedial action for the remnant deposits is in-place containment. These areas will be covered with an 18 inch thick layer of subsoil followed by a 6 inch layer of topsoil. The cover will then be graded and seeded to minimize erosion and, in appropriate "" areas, raised to ensure the integrity of the site. Where necessry, bank stabilization will be performed along the riverbank in the form of riprap. Fencing and posting will be placed, where necessary, to restrict public access. ------- IV. Flood Plain Regulatory Requirements In accordance with Executive Order 11988, Floodplain Management, an applicable executive agency shall provide leadership and shall take action to reduce the risk of flood loss, to minimize the impact of floods on human safety, health and welfare, and to restore and preserve the natural and beneficial values served by floodplains. In addition, it is necessary to evaluate the potential effects of any action that may be taken in a floodplain and that potential harm is minimized. The following agencies would be involved in any floodplain management efforts: o United States Environmental Protection Agency o U.S. Army Corps of Engineers o Federal Emergency Management Agency o New York State - Department of Environmental Conservation - Department of Transportation o Town and Villages bordering on the Hudson River. As a responsibility under the cooperative agreement . between the USEPA and the NYSDEC the appropriate agencies and concerned groups will be kept abreast of proposed design design and construction activities. The EPA in conjunction with the NYSDEC has determined that the proposed activities for the remnant sites are the most practical option available in light of current funding limitations and technical constraints. An option that was evaluated as being the most-effective in removing the PCB vectors would require complete removal of the remnant sites. If this option were implemented, the floodplain upstream would result in a " ""larger cross-section. It must be pointed out that major charges in the floodplain were incurred as a result of the removal of the Fort Dam in 1973, since the levels of river water decreased upstream. V. Flood Hazard Assessment The flood hazard associated with this project would be in the upstream effects of introducing trill material onto the remnant sites. The proposed action would provide a soil cap on the remnant sites as well as securing the banks to contain PCBs at the sites and deter erosion into the river, as well as, eliminating the direct human contact vector. ------- -5- Based upon the data available, which are depicted in the attached figures, the amount of fill necessary to raise the sites above the 100 year flood level is insignificant since the majority of the remnant sites are currently above the flood elevation. There should therefore be insignificant adverse impacts on the surrounding environment during flooding. The design of the proposed action will incorporate erosion control in the form of o Riprap shoring of banks o Vegetative protection o Future maintenance The beneficial effects on the human environment and the river ecosystems by containing/controlling this PCS source greatly outweigh the minimal if any impacts on the 100 year floodplain by the proposed action. ------- MMNANT AM* 4 •O»OO-v/-"^ - MMNANT AM A I SARATOGA COUNTY COVIMO BV TMf 100 VKAN FLOOD ;•""'> LIMIT Of 100 YEAR FLOOD STAGE FIGURE I PLAN VIEWj REMNANT DEPOSITS HUDSON RIVER PCB SITE. HUDSON RIVER. NY SCALE' I = 2,000 IMUS __LJ OCDRPORAT1DN ------- WEST EAST 160 UJ u. UJ UJ UJ ay I4O £ o S 130 UJ 12° 0 100 YEAR FLOOD 8ROUNO SURFACE AVO. ANNUAL FLOOD 90% DURATION FLOW AVO. CONTAMINATED DEPTH 200 DISTANCE (FEET) 400 SOURCE' TRANSECT 92+OO, MALCOLM PIRNIE (1977) TYPICAL CROSS SECTION AT REMNANT DEPOSIT 1 HUDSON RIVER PCB SITE. HUDSON RIVER. NY FIGURE VIIMUS I nORFCWAnarvJ A Haftburibn Company ------- Ul WEST fc UJ u. UJ UJ CO UJ g ISO 140 130 UJ _J UJ 120 AVO. CONTAMINATED DEPTH EAST GROUND SURFACE ^ AVO. ANNUAL FLOOD EXISTING BANK BANK BEFORE MARCH 1976 „„ FLOOD 200 DISTANCE (FEET) 400 SOURCE1 TRANSECT 80+OO, MALCOLM PIRNIE (1977) TYPICAL CROSS SECTION AT REMNANT DEPOSIT 2 HUDSON RIVER PCB SITE, HUDSON RIVER, NY FIGURE IIMUS r CCJRPORATIDN A Halliburton Company ------- WEST EAST UJ UJ UJ UJ UJ CO o at 146 135 125 _ UJ IIS ASSUMED TOP OF STONE RIP-RAP 0 ROUND SURFACE AVO. ANNUAL FLOOD AVO. CONTAMINATED DEPTH 200 DISTANCE (FEET) 400 SOURCE- TRANSECT S244O, MALCOLM PIRNIE (1977) TYPICAL CROSS SECTION AT REMNANT DEPOSIT 3 HUDSON RIVER PCB SITE, HUDSON RIVER, NY FIGURE* TCT PHIMUS _LJ CORPORATOr ------- WEST EAST **! UJ 2 UJ UJ o 145 135 125 UJ _J UJ 115 GROUND SURFACE AVG. CONTAMINATED DEPTH I ASSUMED TOP OF STONE RIP-RAP AVO. ANNUAL FLOOD 90% DURATION FLOW 20O DISTANCE (FEET) 400 SOURCE' TRANSECT 2O»OO, MALCOLM PIRNIE (1977) TYPICAL CROSS SECTION AT REMNANT DEPOSIT 4 HUDSON RIVER PCB SITE, HUDSON RiVER. NY FIGURE IMUS CXDRPORATION if A Hallkburion Company ------- o> u UJ UJ UJ en O 0) g 1 ui _j Ul WEST EAST 145 135 125 115 GROUND SURFACE ASSUMED TOP OF STONE RIP-RAP 100 YEAR FLOOD 90% DURATION FLOW AVO. ANNUAL FLOOD AVO. CONTAMINATED DEPTH 200 DISTANCE (FEET) 40O SOURCE' TRANSECT 2+OO, MALCOLM PIRNIE (1977) TYPICAL CROSS SECTION AT REMNANT DEPOSIT 5 HUDSON RIVER PCB SITE, HUDSON RIVER. NY FIGURE -V-L- IMUS CORPORATTOM ------- \ ?/EPA News Release 82(69) Call: Jim Marshall (212)264-2515 FOR RELEASEi Thursday, December 30, 1982 EPA WILL ADDRESS HUDSON RIVER PCBs THROUGH •SUPERFUND* The U.S. Environmental Protection Agency (EPA) today announced that it will not use the Clean Water Act to fund a demonstration project to remove Hudson River sediments from Albany north to Fort Edward that are contaminated with polychlorinated biphenyls (PCBs). Instead, EPA Administrator Anne M. Gorsuch has determined that the problem should be addressed by means of the Comprehensive Environmental Response, Compensation and Liability Act (CEHCLA, or "Superfund"). Section 116 of the Clean Water Act required the Administrator to determine whether funds are available from sources other than the Clean Water Act, including Superfund. This means that more than $18 million in Federal sewage treatment funds that had been set aside for the PCB project will now become available for sewage projects in Mew York State. Today's action is the final step in an environmental impact analysis process to evaluate a demonstration project authorized by Section 116 of the Clean Water Act. In the $26.7 million project only 30 to 35% of the contaminated sediments would be selectively removed and disposed of in a secure landfill in Washington County. ------- -2- Jacqwelina 8. Scbrnfmr, DA'S regional administrator la Sew York, pointed out that •thl» extaamiiej analysis ha« failad to persuade WA that the partial dredging projact would significantly banafit tha Hudaon Rlvar fishery, ineraaaa tha protaction of drinking watar or raduea tha riak of PCS contamination south of Albany.' * *-• -, •Howaver," aha added, *wa believe enough concern still exists about tha potantial for futura contamination of drinking water or exposure of tha * * — - • . ^ public to tha contaminated raonant dapoaita at Port Edward to warrant a further look under CBC1A." K preliminary calculation by EPA ahowa that tha Hudaon River KB problem would acore high enough for ineluaion on tha propoaad CEPCLA National Priority Liat of aitaa for poaaibla action. It is anticipated that the site will be added shortly after tha proposed list becomes final. Inclusion of the site on tha list will trigger tha following actions (most of the neaded data and studies were developed during the environmental impact analysis) • Preparation of a Remedial Action Master Plan {RAMP) to determine whether initial steps to protect the public health are required and whether additional monitoring ot sampling is needed; • A search to identify responsible parties; • Preparation of a feasibility study addreaaing such questions as whether any threat could be mitigated by controlling tha remnant deposits, whether off-site remedial action may be required because of continued migration of PCBs, and what alternative actions (including no action) may be feasible and coat affective. ------- -3- Zf a Superraad-fiMneejd action is found to be appropriate, a fond-balancing i analysis »u«t be> perforaed to ensure th* action would provide a cost- effective response that balances the need to protect public health and the environaent at this site with the availability of Soperfund dollars to • * respond to other sites. Consistent with EPA policy, the agency will also initiate enforcement Measures to pursue a privately funded response to the problea. These aeasures may include a search to identify responsible parties; notice to these parties that Superfund action may be taken and an opportunity, through negotiation, for then to undertake the action; or other appropriate enforcement measures. If Superfund monies are used, state cost sharing is required. Copies of today's determination and EPX's Recdrd of Decision are being mailed to all interested parties. It* ------- N.Y, 10007 EPA News Release 83(96) James Marshall (212) 264-2515 FOR RELEASE: October 13, 1983 EPA SCHEDULES PUBLIC MEETING ON PCBs IN THE HUDSON RIVER NEW YORK — The U.S. Environmental Protection Agency (EPA) has scheduled a public meeting to discuss the draft feasibility i study which looks at alternative remedies for the problem of Hudson River sediments that are contaminated with polychlorinated biphenyls (PCBs) above Albany, N.Y. The draft feasibility study considered 36 alternative clean- up plans including a number of new PC3 treatment and destruction technologies. All reasonable alternatives were considered. The. meeting will be held November 3rd, 1983 from 3:00 PM to 5:30 PM and 7:00 PM to 9:00 PM in Meeting Room 1 on the Concourse Level at Governor Nelson A. Rockefeller Empire State Plaza. Copies of the study are available for public inspection and review at the following locations: NYS Department of Environmental Conservation (DEC) 202 Mamaroneck Avenue White Plains, N.Y. -more- ------- DEC DEC, Division of Water, Rm. 201 21 South Putt Corners Rd. 50 Wolf Road New palt*, N.Y. Albany, N.Y. DEC Crandall Library 2 World Trade Center • City Park Room 6126 Glens Falls, N.Y. New York, N.Y. The public comment period on the study opened on October 7th and is scheduled to close on 'November 7th. All written comments and requests to speak at the public meeting should be mailed to: Robert Raab, Project Officer Office of Emergency and Remedial Response U.S. Environmental Protection Agency Region II 26 Federal Plaza, Room 402 New York, N.Y. 10278 *** ------- Ul PRELUMNARV REMEDIAL MVESTKATION ACTIVITIES TASK 1 - PREPARE Rl WORK PLAN TASK I - PERFORM COMMUNITY RELATIONS SUPPORT FUNC TUNS TASK 1 - COLLECT AND EVALUATE EXISTING DATA TASK* - PERFORM HEALTH, SAFETY. AND GENERAL SITE RECONNAISSANCE TASK* - SECURE PERMITS, MGHT* OF ENTRY AMD OTHER AUTHORIZATIONS TASK* . PROCURE SUBCONTRACTORS TASK; - DEVELOP SITE-SPECRTC HEALTH AND SAFETY PLAN • TASKI - DEVELOP SITE-SPEOFIC QUALITY ASSURANCE PLAN TASK* - DEVELOP SITE-SPECnC SAMPLING PLAN TASK 10 . M06R.IZE FIELD EQLNPMENT SITE REMEDIAL INVESTIGATION ACTIVITIES TASK II - PERFORM GROUND SURVEY TASK II - PREPARE TOPOGRAPMC MAP f ' TASK 11 - COLLECT SURFACE SOIL SAMPLES TASK 1* - REDUCE AND EVALUATE DATA < TASKI) - PREPARE REMEDIAL INVESTIGATION REPORT 1 • •R- f • f • F • • • F M L II it i ii rlAi 14 1 01 II «II INI l rfti (•1 RB • I* t •• pi 4 It u L u • u • X X •I Ul •• I . CONTRACTOR ACTIVITY PERIODIC CONTRACTOR ACTIVITY AS REQUIRED EPA/NYSDEC REVIEW REMEDIAL INVESTIGATION PROJECT SCHEDULE. REMNANT DEPOSITS HUDSON RIVER PCB SITE. HUDSON RIVER. 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