IMUS CORPORATION Park West Two Cliff Mine Road Pittsburgh, PA 15275 412-788-1080 R-31-7-3-5 HR VOLUME I FEASIBILITY STUDY HUDSON RIVER RGBs SITE NEW YORK EPA WORK ASSIGNMENT NUMBER 01-2V84.0 CONTRACT NUMBER 68-01-6699 NUS PROJECT NUMBER 0723.01 APRIL 1984 SUBMITTED FOR NUS BY: STEPHEN F. PEDERSEN, P.E. PROJECT MANAGER APPROVED: 6 Jki^^v £1 E. DENNIS ESCHER, P.E MANAGER, REMEDIAL PLANNING pA Halliburton Company ------- CONTENTS SECTION PAGE EXECUTIVE SUMMARY ES-i 1.0 INTRODUCTION 1-1 1.1 BACKGROUND 1-1 1.2 SETTING 1—2 1.3 SCOPE OF WORK 1-6 2.0 ThE SF E 2—1 2.1 LOCATION 2-1 2.2 SITE HISTORY 2-4 2.3 POTENTIAL SOURCES OF CONTAMINATION 2-5 2.4 RESPONSE ACTIONS TO DATE 2-6 3.0 ENVIRONMENTAL SETTiNG 3-1 3.1 LANDFORMS 3-1 3.2 SURFACE WATERS 3-1 3.3 GEOLOGY AND SOILS 3-2 3.3.1 BEDROCK GEOLOGY 3-2 3.3.2 SURFICIAL GEOLOGY 3-5 3.3.3 SOILS 3—10 3.4 GROUNDWATER 3-11 3.5 CLIMATE AND METEOROLOGY 3-12 3.6 LAND USE 3-14 3.7 WATER USE 3-15 3.7.1 SURFACE WATER USE 3-15 3.7.2 GROUNDWATER USE 3-17 4.0 ENVIRON MENTAL CONCENTRATIONS 4-1 4.1 CONCENTRATIONS, DISTRIBUTION AND TRENDS 4-1 4.1.1 SEDIMENTS 4-1 4.1.2 WATER 4-33 4.1.3 AIR 4—51 4.1.4 BIOTA 4—53 4.2 ADEQUACY OF EXISTING DATA BASE 4-67 4.2.1 REMNANT DEPOSITS 4-67 4.2.2 SEDIMENT 4—67 4.2.3 WATER 4—69 4.2.4 AIR 4—70 4.2.5 BIOTA 4—70 4.3 EVALUATION OF PCB TRANSPORT MODEL 4-70 4.3.1 HYDRAULIC SUBMODEL 4-71 4.3.2 SEDIMENT TRANSPORT SUBMODEL 4-76 4.3.3 PCB INVENTORY SUBMODEL 4-84 4.3.4 SUMMARY AND CONCLUSiONS 4-96 ------- CONTENTS (CONTINUED) SECTION PAGE 5.0 PUBLIC HEALTH CONCERNS 5-1 5.1 DISCUSSION OF PCBs 5-1 5.2 AIR POLLUTION 5-4 5.3 SEDIMENT CONTAMINATION 5-5 5.4 GROUNDWATER CONTAMINATION 5-6 5.5 SURFACE WATER CONTAMINATION 5-7 5.6 GENERAL RISK ASSESSMENT 5-12 6.0 HEALTH AND SAFETY PROCEDURES 6-1 81 PERSONAL HEALTH AND SAFETY PROTECTION 6-1 6.1,1 REMEDIAL INVESTIGATION 6-1 6.1.2 REMEDIAL ACTION 6-2 6.2 HEALTH AND SAFETY MONITORING 6-4 7.0 REVIEW OF NEW TECHNOLOGY 7-1 7.1 TREATMENT PROCESSES 7-3 7 1.1 ACUREX 7-3 7.1.2 BIOLOGICAL SYSTEMS 7-3 7.1.3 CONTROLLED AIR INCINERATOR 7-4 7.1.4 FLUIDIZED BED INCiNERATOR 7-4 7.1.5 GOODYEAR 7-4 7.1.6 HYDROTHERMAL 7-4 7.1.7 KOHPEG 7-5 7.1.8 LARC 7—5 7.1.9 MOLTEN SALT INCINERATOR 7-5 7.1.10 NaPEG 7—6 7.1.11 OZONATION 7-6 7 1.12 PCBX 7—6 7.1.13 PHOTODECOMPOSITION 7-7 7.1.14 PLASMA ARC 7-7 7.1.15 PYROMAGNET1CS INCINERATOR 7-7 7.1.16 ROTARY KILN 7-7 7.1.17 THAG.ARD HTFW 7-8 7.1.18 ULTRAVIOLET/OZONE 7-8 7.1.1 WET-AIR OXIDAT 1ON 7-8 7.2 ANALYTICAL PROCESS 7-9 8.0 INVESTiGATION OF REMEDiAL ALTERNATIVES 8-1 8.1 REVIEW OF PREVIOUSLY DEVELOPED ALTERNATIVES 8-1 8.1.1 ALTERNATIVES FOR PCBs IN RIVER SEDIMENTS 8—1 8.1.2 ALTERNATIVES FOR PCBs IN REMNANT DEPOSIT AREAS 8-12 8.2 REVIEW OF NEW ALTERNATIVES 8-16 8.3 REVIEW OF POSSIBLE COMBINATIONS OF ALTERNATIVES 8-18 8.3.1 RIVER SEDIMENTS 8-19 8.3.2 REMNANT DEPOSITS 8-21 II ’ ------- CONTENTS (CONTINUED) SECTION PAGE 8.4 PRELIMINARY SCREENING OF ALTERNATIVES 8-23 8.4.1 SCREENING OF DETOXIFICATION OR DESTRUCTION 8-24 TECHNIQUES 8.4.2 SCREENING OF SINGLE ALTERNATIVES 8-27 8.4.3 SCREENING OF COMBINATIONS OF ALTERNATIVES 8-29 9.0 EVALUATION OF ALTERNATIVES 9-1 9.1 METHODOLOGY FOR EVALUATION OF ALTERNATIVES 9-1 9.2 CRITERIA FOR EVALUATION OF ALTERNATIVES 9-1 9.2.1 EFFECTIVENESS MEASURES 9—1 9.2.2 COSTS 9-5 9.2.3 WEIGHTING FACTORS 9-7 9.3 EVALUATION OF ALTERNATIVES 9-8 9.3.1 EXAMINATION OF REMAINING ALTERNATIVES 9-8 9.3.2 EVALUATION PROCEDURE 9-62 9.3.3 SELECTION OF COST-EFFECTIVE ALTERNATIVE 9-64 9.3.4 SENSITIVITY ANALYSES 9-68 9.3.5 SUMMARY 9-69 10.0 REMEDIAL ACTION PLANNING ACTIVITIES 10-1 10.1 SITE REMEDIATION OBJECTIVES 10-1 10.2 REMEDIAL ACTION FOR THE HUDSON RIVER PCBs SITE 10-1 10.2.1 FINAL DESIGN 10—1 10.2.2 IMPLEMENTATION 10-2 10.2.3 ENVIRONMENTAL MONITORING 10-3 10.3 PRELIMINARY WORK PLAN OUTLINE FOR THE REMEDIAL 10-4 INVESTIGATION OF THE REMNANT DEPOSIT SITES 10.3.1 WORK PLAN SUMMARY 10-4 10.3.2 PROBLEM ASSESSMENT 10-4 10.3.3 SCOPE OF WORK 10—5 10.3.4 MANAGEMENT PLAN 10-10 10.3.5 COSTS AND SCHEDULE 10-11 10.4 PRELIMINARY WORK PLAN OUTLINE FOR PHASE I 10-11 OF THE REMEDIAL INVESTIGATION OF THE RIVER 10.4.1 WORK PLAN SUMMARY 10-11 10.4.2 PROBLEM ASSESSMENT 10-12 10.4.3 SCOPE OF WORK 10—12 10.4.4- MANAGEMENT PLAN 10-26 10.4.5 COSTS AND SCHEDULE 10—27 Iv ------- CONTENTS (CONTINUED) SECTION PAGE REFERENCES R—i APPENDICES A SITE CHRONOLOGY HUDSON RIVER PCBs SITE, NEW YORK A-i B COST EFFECTIVENESS MATR iCES B—I C AL7ERNATIVE COST ESTIMATES C-I D PHASE II. REMEDIAL INVESTIGATION OF THE 0 -i HUDSON RiVER E ANALYSIS OF 1983 SAMPLING DATA E-1 F REMEDIAL INVESTIGATION COSTS AND SCHEDULESI F - i REMEDIAL ACTION CONSTRUCTION SCHEDULES V ------- TABLES NUMBER PAGE ES-i REMEDIAL ALTERNATIVES AND COST COMPARISONS ES-13 1-1 NYSDEC RECOMMENDED PROGRAM 1-3 1—2 EPA RECOMMENDED PROGRAM (DE1S) (MAY 1983) 1-5 2-1 ESTIMATED MASS OF PCB IN THE HUDSON RIVER BASiN 2-7 3-1 CLIMATE AND METEOROLOGY - ALBANY COUNTY AIRPORT 3-13 4-1 PCB CONTAMINATION IN REMNANT DEPOSITS 4-4 4-2 STATISTICAL CHARACTERISTICS OF PCB AND PCB MASS ESTIMATES FOR RIVER REACHES IN THE UPPER HUDSON RIVER 4-12 4-3 CONTAMINATED AND REMOVAL VOLUMES AND PCB QUANTiTIES 4-25 4-4 CONTAMINATION OF PCBs (Aroclor 1242) IN RECENT SEDIMENTS OF THE LOWER HUDSON RIVER 4-30 4-5 PRELIMINARY PCB BALANCE FOR THE LOWER HUDSON 4-32 4-6 COMPARISON OF SURVEY DATA FROM SUSPECTED HOT SPOTS IN THE LOWER HUDSON RIVER 4-34 4-7 PHYSiCAL PHASE OF PCBs IN WATER COLUMN (WATERFORD) 4-36 4-8 AVERAGE PCB CONCENTRATIONS FOR THREE FLOW REGIMES - FOR 1977-1979 USGS DATA 4-40 4-9 LOW FLOW PCB CONCENTRATIONS 4-41 4-10 RECENT FLOW DATA FROM THE GAGING STATION AT STILLWATER 4-45 4-11 CALCULATED PCB MIGRATION POTENTIAL FROM CONTAMINATED LANDFILLS AND DREDGE SPOIL AREAS IN THE UPPER HUDSON RIVER AREA 4-49 4-12 PCB LOSSES TO THE RECEIVING STREAMS 4-50 UNSECURE DREDGE DISPOSAL SITES 4-13 TOTAL SUSPENDED PARTICULATES - HIGH VOLUME AIR SAMPLERS, SELECTED STATIONS - UPPER HUDSON RIVER, 1976 4—52 4-14 NEW YORK STATE DEPARTMENT OF HEALTH, PCB AIR SAMPLING 4_54 4-15 SUMMARY TABULATION OF AIR PCB DATA BY NYSDEC DIVISION OF AIR RESOURCES 4-56 4-16 LIPID-BASED AND WET-WEIGHT-BASIS PCB CONCENTRATIONS IN FRESH WATER RESIDENT FISH SPECIES 4—58 4-17 LIPID-BASED AND WET-WEIGHT-BASIS PCB CONCENTRATIONS IN MARINE SPECIES 4-60 4-18 CURRENT APPROXIMATE AVERAGE TOTAL PCB CONCENTRATIONS IN HUDSON RIVER MIGRANT/MARINE FISH (WET BASIS) ENCOUNTERED BELOW TROY 4-64 5-1 PCB CONCENTRATIONS, HOT SPOTS AND WETLANDS 5-2 5-2 PCB LEVELS IN THE VILLAGE OF WATERFORD 5-9 DRINKING WATER VI ------- TABLES (CONTINUED) NUMBER PAGE 5-3 PCB CONCENTRATION OF UNTREATED AND FINISHED DRINKING WATER 5-10 5-4 PCB LEVELS IN WATERFORD DRINKING WATER 5-11 8-1 PCB TRANSPORT PROJECTIONS USING LMS MODEL 8-2 DATA COMPARED WITH TRANSPORT PROJECTIONS USING CURRENT ESTIMATED TRANSPORT RATE 8-2 TECHNOLOGY STATUS AND APPLICABILITY 8-17 9-1 WEIGHTiNG FACTORS FOR EFFECTIVENESS MEASURES 9-9 9-2 SUMMARY OF COST-EFFECTIVENESS RATINGS 9-66 FIGURES NUMBER PAGE 2-lA PROJECT AREA. UPPER HUDSON RIVER 2-2 2-lB PROJECT AREA, LOWER HUDSON RIVER 2-3 3-1 STRATIGRAPHIC SECTION - BEDROCK 3-3 3-2 STRATIGRAPHIC SECTION - UNCONSOLIDATED MATERIAL 3-7 3-3 SURFICIAL GEOLOGY OF SARATOGA COUNTY 3-8 3-4 SURFICIAL GEOLOGY OF WASHINGTON COUNTY 3-9 4-1 PLAN VIEW, REMNANT DEPOSITS 4-2 4-2A TYPICAL CROSS SECTION AT REMNANT DEPOSIT 1 4-5 4-2B TYPICAL CROSS SECTION AT REMNANT DEPOSIT 2 4-6 4-2C TYPICAL CROSS SECTION AT REMNANT DEPOSIT 3 4-7 4-2D TYPICAL CROSS SECTION AT REMNANT DEPOSIT 4 4-8 4-2E TYPICAL CROSS SECTION AT REMNANT DEPOSIT 5 4-9 4-3 ESTIMATED PCB IN POUNDS BY RIVER POOL, 4-15 HUDSON RIVER PCB SITE, HUDSON RIVER, NEW YORK 4-4 HOT SPOT AND REMNANT AREA LOCATIONS 4-17 4-4A PLAN VIEW - UPPER HUDSON RIVER AREA 4-18 4 4B PLAN VIEW - UPPER HUDSON RIVER AREA 4-19 4-4C PLAN VIEW - UPPER HUDSON RIVER AREA 4-20 4-4D PLAN VIEW - UPPER HUDSON RIVER AREA 4-21 4-4E PLAN VIEW - UPPER HUDSON RIVER AREA 4-22 4-4F PLAN VIEW - UPPER HUDSON RIVER AREA 4-23 4-4G PLAN VIEW - UPPER HUDSON RIVER AREA 4-24 v i i ------- FIGURES NUMBER PAGE 4-5 RELATIONSHIP BETWEEN FLOW RATE AND TOTAL PCB 4-37 CONCENTRATION FOR SCHUYLERVILLE AND STILLWATER DATA 4-6 YEARLY PCB TRANSPORT ESTIMATES 4-43 4-7 RELATION OF PCB LOAD TO FLOW RATE DURING SPRING 4-47 FLOOD FLOWS AT WATERFORD 4-8 HEC-6 HYDRAULIC CALIBRATION LOCK 7 TO THOMPSON 4-74 ISLAND DAM REACH 4-9 APPROXIMATE RATING CURVE TO ILLUSTRATE DEFICIENCIES 4-75 IN HYDRAULIC SUBMODEL CALIBRATION 4-bA SUSPENDED AND TOTAL SEDIMENT LOAD VS FLOW, HUDSON 4-77 RIVER, GLENS FALLS, NEW YORK 4-lOB TOTAL SEDIMENT LOAD VS FLOW, MODEL CALIBRATION - 4-78 PERIOD DECEMBER 1976 - MAY 1977 4-1OC TOTAL SEDIMENT LOAD VS FLOW, MODEL CALIBRATION 4-79 PERIOD DECEMBER 1976 — MAY 1977 4-1OD TOTAL SEDIMENT LOAD VS FLOW, MODEL CALIBRATION 4-80 PERIOD DECEMBER 1976 - MAY 1978 4-11 COMPARISON OF SEDIMENT LOAD VS FLOW, 4-83 RELATIONSHIPS AT VARIOUS MONITORING STATIONS 4-12 PCB WATER COLUMN CONCENTRATION VS FLOW 4-86 COMPARiSON: MODEL PCB RESULTS AND USGS DATA,. MODEL CALIBRATiON PERIOD DECEMBER 1976 - MAY 197? 4-13 PCB WATER COLUMN CONCENTRATION VS FLOW 4-88 COMPARISON: PCB MODEL RESULTS AND USGS DATA, LOCK 4 4-14 GREEN ISLAND, PCB LOAD VS FLOW, MODEL CALIBRATION 4-89 PERIOD DECEMBER 1976 - MAY 1977 4-15 TOTAL PCB LOAD VS FLOW COMPARISON: PCB MODEL 4-90 RESULTS AND USGS DATA, MODEL CALIBRATION PERIOD DECEMBER 1976 - MAY 1977 4-16 COMPARISON OF TOTAL PCB LOAD VS FLOW AT VARIOUS 4-92 MONITORING STATIONS (OCTOBER 1975 - SEPTEMBER 1977) 4-17 COMPARISON OF PCB CONCENTRAT1ON VS FLOW AT VARIOUS 4-93 MONITORING STATIONS (OCTOBER 1975 - SEPTEMBER 1977) 4-18 COMPARISON OF PCB CONCENTRATION VS FLOW AT VARIOUS 4-94 MONITORING STATiONS (OCTOBER 1977 - APRIL 1979) 8—1 FLOW CHART OF INITIAL SCREENING PROCESS 8-25 9—1 COST EFFECTIVENESS MATRIX 9-63 9-2 REMEDIAL ALTERNATiVE EVALUATION - FLOW DIAGRAM 9-65 V I II ------- GLOSSARY I cts (cubic feet per second) = 448.83 gpm (gallons per minute) 1 MGD (million gallons per day) = 694.4 gpm (gallons per minute) 1 1/mm (liters per minute) = 0.26418 gpm (gallons per minute) 1 m 3 /sec (cubic meters per second) = 15,850.3 gpm (gallons per minute) 1 ton/day (tons per day) = 730,480 lb/yr (pounds per year) 1 lb/yr (pounds per year) = 0.002738 lb/day (pounds per day) 1 lb/day (pounds per day) 0.0417 lb/hr (pounds per hour) 1 lb/hr (pounds per hour) = 0.0167 lb/mm (pounds per minute) 1 ig/day (micrograms per day) = 2 203 x 109 lb/day (pounds per day) 1 lb (pound) = 0.45359 kg (kilograms) 1 ppm- (parts per million) = 1 ug/g (micrograms per gram) 1 ppb (parts per billion) 1 ig/l (micrograms per liter) 1 j g/g (milligrams per gram) 1 ppm (parts per million) 1 ig/l (micrograms per liter) 1 ppb (parts per billion) 1 mg/I (milligram per liter) 1 ppm (parts per million) 1 g/m 3 (micrograms per cubic meter) 1000 ng/m 3 (nanograms per cubic meter) 1 cu yd (cubic yard ) = 0.76456 m 3 (cubic meters) 1 yd (yards) 0.91440 m (meters) 1 ft (feet) = 0.30480 rn (meters) 1 in (inches) 2.540 cm (centimeters) 1 ac (acres) 43,560 sq ft (square feet) DEIS — Draft Environmental Impact Statement EIS — Environmental Impact Statement EPA — Environmental Protection Agency F.D.A. — U.S. Food & Drug Administration NEPA — National Environmental Policy Act NIOSH — National Institute of Ocbupational Safety and Health NYSDEC — New York State Department of Environmental Conservation NYSDOH — New York State Department of Health PCB — polychiorinated biphenyl SDEIS — Supplemental Draft Environmental Impact Statement SEQIS — State Environmental Quality Review Act Environmental Impact Statement USGS — United States Geological Survey DFS — Draft Feasibility Study Receptor — Person or persons who could be potentially exposed to PCB occurring in air, water, sediment, soil, or biota. ix ------- EXECUTIVE SUMMARY The Feasibility Study for the Hudson River PCB site is prepared in accordance with the rules of the National Contingency Plan (NCP) published pursuant to Section 105 of the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA). The original Work Assignment issued by EPA was for the development of a Remedial Action Master Plan (RAMP). Before the RAMP was completed, the Hudson River PCBs Site was placed on the EPA’s National Priorities List, and, as a result, became eligible for the funding of remedial actions. Since the elements required by the Work Assignment are equivalent to those for a feasibility study under CERCLA, the title of the document was changed to a Draft Feasibility Study (DFS). The Draft Feasibility Study was submitted for public review in October of 1983, and was subsequently revised to reflect many of the concerns expressed in public comments. The final document includes those changes and is entitled “Volume I — Final Feasibility Study” although the title of RAMP is used in the text to eliminate wide—spread revision. A separate document contains detailed responses to individual comments and is entitled “Volume II Responses to Comments, Feasibility Study, Hudson River PCBs Site, New York.” A significant amount of scientific and engineering information currently exists regarding the problems of PCBs in the Hudson River, and this ‘information was used in the preparation of this document. Major objectives of the Feasibility Study were to reevaluate a previously prepared environmental impact statement and subsequently to compile a list of proposed and newly devisoped remedial alternatives. These alternatives were evaluated using a cost—effective approach consistent with the goals and objectives of CERCLA. ES-i ------- The Site 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 Hudson 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 (Upper Hudson River) is a high—gradient, fresh—water stream confined by 15 dams. The 30—mile reach in the Upper Hudson River between Albany and Fort Edward is officially part of the New York State Barge Canal System and is maintained and regulated by the State Department of Transportation. Over a 30—year period ending in 1977, two General Electric (GE) 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 were 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 1.1 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 887,000 to 1.1 million pounds of PCB throughout the entire Hudson River, System south of Fort Edward. Today, it appears that much of this PCB has either been dredged or washed out to sea so that only 498,000 to 656,000 pounds remains in the river. GE Is also reported to have placed an additional 528,000 to 745,000 pounds of PCB in upland dumps. The latter PCBs are not directly related to the Hudson River problem. Action brou ht against GE by th New York State Department of Environmental Conservation (NYSDEC) in 1975 resulted in a 7—million—dollar program for the investigation of PCBs and the development of methods to reduce or remove the ES-2 ------- threat of PCB contamination. Subsequent sediment surveys revealed that the most extensive contamination was confined to 40 submerged PCB hot spots 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 NYSDEC studies 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 severe 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 hydroelectricity. For these reasons, NYSDEC proposed a partial cleanup of the river by dredging selected PCB hot spots and containing them In a secure upland containment facility. 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 If the EPA Administrator determined that funds were not first available under Section 115 or 311 of the CWA or from the then proposed CERCLA. Congress authorized the EPA to make grants to the New York State Department of Environmental Conservation (NYSDEC) in order to carry out the intent of the Act. As a result of Federal involvement and in accordance with the National Environmental Policy Act (NEPA) and requirements In Section 116, the EPA Region II, on May 8, 1981, issued a Draft Environmental 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), 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 ES-3 ------- considered for inclusion on the National Priorities List. The Hudson River PCBs Site was included on the currently proposed update of the National Priorities List issued in August 1983. Although the funding authorization of Section 116 was due to expire on September 30, 1983, the Administrator of EPA has extended the option to support a demonstration project with CWA funds under the conditions that NYSDEC develop a suitable disposal method and redefine the extent of river contamination. Environmental Setting The environment affected by the Hudson River PCB problem Includes all waters, lands, ecosystems, communities, and facilities located in -or Immediately adjacent to the 200—mile stretch of river from Fort Edward to the Battery. This project focuses on, but is not limited to, the most heavily contaminated reach between Albany and Fort Edward (Upper Hudson River). Problems and possible actions involving PCBs in upland dumps within the Upper Hudson River Basin are not within the scope of this study. Likewise, dredge spoils, although possibly contributing very minor quantities of PCBs to the present problem are not directly within the scope of the report since they are being addressed by NYSDEC and GE In a separate agreement, not related to the Hudson River project. The surficlal sediments near the Upper Hudson River vary In thickness from a few Inches to more than 200 feet and consist of unconsolidated materials including till, glacial outwash deposits, proglacial lacustrine deposits, recent alluvium, and modern dredge spoils. The underlying bedrock Is predominantly folded and fractured, black Ordovician shale. The climate of the area Is continental; however, seasonal variations In temperature and precipitation are often moderated by the maritime climate which prevails In the southeastern portion of the state. The annual average temperature of the area is 47°F and the annual precipitation totals an average of 30 inches. ES-4 ------- The mean annual discharge at Stlllwater, located midway between Fort Edward and Albany, is about 6.000 cubic feet per second (cfs). River flows are regulated by five reservoirs above Fort Edward. The mean annual flood flow at Stiilwater (approximately 31,000 cfs) usually generates flow velocities sufficient to cause scouring of the banks and river bottom. Land use in the Upper Hudson River area is predominantly agricultural. Petroleum refineries, grain bins, and paper mills are located at various sites along the river. Albany is the largest population center along the upper Hudson River. Other cities with populations greater than 25,000 are Troy, Poughkeepsie, Newburgh, and New York. New York, and Newark, New Jersey. The Hudson River Is an important source of hydroelectric power, public water supplies, transportation, and recreation. The Upper Hudson River is the greatest hydroelectric—producing area in the basIn, with a total of 10 plants located above Fort Edward. Waterford, New York Is supplied with drinkIng water by the Upper Hudson River. The city of Poughkeepsie, the Highland Water DIstrict, Port Ewen Water District, and the village of Rhinebeck take their water supplies directly from the Lower Hudson River. A water intake located at Chelsea, which is north of Beacon, New York. may be used to suppiement New York City water supplies during periods of drought. Environmental Concentrations More than 1,200 core and grab samples from the Upper Hudson River bottom, taken by NYSDEC and other agencies in 1977 and 1978, revealed the following: • That fIve exposed remnant deposits left in the former Fort Edward Dam pool, with average PCB concentrations ranging from 5 to 250 parts per million (ppm), contained from 63,820 to 139, 820 pounds of PCBs. 1 1 Since the removal of remnant area 3A in 1978, the estimate is 46,800 to 108,000 pounds. ES—5 ------- • That 40 PCB hot spots located in the Upper Hudson River between Fort Edward and Albany contained from 158,000 to 170,000 pounds of PCBs. These hot spots were of limited areal extent and had average PCB concentrations in excess of 50 ppm. • That extensive cold areas# of the Upper Hudson River, with average PCB concentrations of 20 ppm, contained from 123,000 to 177,000 pounds of PCBs. Separate sampling surveys by other NYSDEC consultants revealed that Lower Hudson River sediments had an average PCB concentration of about 10 ppm and contained from 169,000 to 200,000 pounds of PCBs. The total mass of PCBs residing In Hudson River sediments and remnant deposits Is estimated at 498,000 to 656,000 pounds. When every known source of PCB Is considered, including PCBs in dredge spoils, and upland dumps, as well as those PCBs washed out to sea, the final total of PCB associated with GE is between 1.4 to 1.8 million pounds. The United States Geological Survey (USGS) has periodically monitored river—water PCB concentrations in the Upper Hudson River at Glens Falls, Rogers Island, Stlllwater, Schuylervllle, and Waterford, New York since 1977. The amount and form of PCBs in the water column have been shown to vary with flow. During low flow periods, PCBs are present mostly In a desorbed form. At flows higher than 21,000 cfs at Waterford, large amounts of PCB are present In an adsorbed form on resuspended sediments. During average flaws, however, PCB concentrations are much lower than at other times, probably because dissolved PCB Is diluted and scour Is occurring at a lower rate. During low flows at Waterford ( , 7000 cfs), PCB concentrations average between 0.6 and 0.7 parts per billion (ppb). At flows above 20,000 cfs, total PCB concentrations Increase to about 1.0 ppb. During average flows, however, total PCB levels decrease to about 0.2 ppb. Low—flow average PCB concentrations have shown a significant decrease since 1977. Existing information Is not sufficient to show whether the decreasing trends will continue. ES—6 ------- A PCB transport model developed for NYSDEC has previously been used to estimate the annual PCB load at the Federal Dam at Troy, and to predict the time period over which PCB—contaminated material would exist In, and continue to be transported out of, the Upper Hudson River. The model was also used by NYSDEC to predict the change in PCB transport rate accompanying various proposed remedial activities. According to a reevaluation carried out in the Feasibility Study, however, the model, appears to overestimate PCB transport rates as well as to overstate the importance of high flows in PCB transport. The model also indicates deposition and scour In river reaches where sediment loads were actually conserved. Recent estimates of PCB transport, developed from USGS monitoring data, show that the annual rate of PCB transport has dropped to about 1500 to 2500 pounds per year. This may contradict the model, which projects a 20—year average PCB transport rate of 6,800 to 7,200 pounds per year. In the Upper Hudson River, wet—weight average PCB concentrations in fish routinely exceeded the Food and Drug Administration (FDA) imposed limit of 5 ppm. PCB concentrations in the migrant marine species of the Lower Hudson River are usually much lower; however, severely contaminated individuals of some species (American eel, striped bass) can be found. The distribution of PCB concentrations in fish Is log normal, indicating that the probability of catching a severely contaminated fish is much lower than that which the arithmetic mean would Indicate. Lipid—based PCB concentrations in fish have shown a decrease of 50 to 90 percent since 1977, and the average PCB content of striped bass dropped to 4.8 ppm in 1983. This decrease, in most cases, may be due to the metabolic elimination of Aroclor 1016, a more volatile PCB compound. The decrease, however, may also be related to some physical cause such as a reduction In the release of dissolved PCB from bed sediments. It Is not known whether exposure of more highly contaminated sediments after flood scouring could lead to an increase in fish contamination. PCB levels in the atmosphere have occasIonally been high near concentrated sources of PCB such as dumps, dredge spoils, and remnant sites; however, river— related air pollution such as that measured near riffles and dams h s been quite low, usually less than 0.01 .tg/cu m. ES—7 ------- Treated drinking water from the Waterford supply system rarely exceeds 0.1 ppb according to USGS studies. According to results of 35 NYSDOH samples, the total PCB concentration of Waterford drinking water averages 0.06 ppb. No study of Waterford drinking water has ever found PCB in excess of 1 ppb, which is the maximum allowable exposure promulgated by the New York State Department of Health (NYSDOH). The data base for the Hudson River PCB problem is quite extensive. There are, however, a number of technical problems with the information. Only one comprehensive sediment survey has been performed on the 40 mIles of the Hudson River which contain hot spots. This analytical survey, completed In 1977 and 1978, consisted of 1200 core and grab samples taken along transverse transects 700 feet or more apart. Some deficiencies In this data are apparent. Because of the distance between transects and the size of the sampling area, only a very small percentage of the river was represented In the survey. It Is possible that many areas of contaminated sediments have not been located. Also, the variability of PCB concentration is very large. within relatively short distances. Therefore, hot— spot delineations are very subjective and the standing estimates of PCB mass in hot spots, as well as in cold areas, are probably subject to a high degree of error. There Is no quantitative estimate of the amount of over or underestimation of PCB quantities. Secondly, although the surveys may have been adequate for planning purposes In 1978, there are questions regarding its validity in 1983. The constant shifting and redistribution of sediments brought about by bedload movement and the seasonal patterns of scour and deposition may have significantly changed the shape, size, and location of hot spots. Documentation of trends in fish contamination has been satisfactory, although other authors have questioned the validity of the statistical analysis performed on the data. Documentation of PCB concentrations in ambient river water has also been satisfactory, and up—to—date Information is readily accessible. Records of PCB ES-8 ------- concentrations In drinking water supplies at Waterford are available from NYSDOH and U.S.G.S. These data provided valuable Information but are not as complete as might be desired. Records of PCB concentrations In other water supplies are not readily available. Air monitoring for PCBs was performed in 1980—1981 near dump sites and remnant deposits, and also near dams where air transport was expected. Air monitoring near receptor sites, along the Hudson River, however, Is lacking. It should be emphasized that the results of the evaluation contained In this report are only as good as the original data provided. Given the lack of knowledge regarding the total quantity of contaminated sediments and their location In 1983, the authors of this Feasibility Study based their selection of alternatives on the 1977 data, assuming no movement. A limited amount of sampling was performed at selected hot spots in August 1983 for comparison with 1977 survey results. The 1983 data suggest that some hot spots may have shifted, while others stayed in place. Before any action Is taken on this project, it is essential that a new and more complete series of PCB analyses in the river be performed so that an accurate knowledge of quantities and locations can be obtained. Public Health Concerns Potential public exposure to PCBs can occur via various routes due to the presence of the compounds In the sediments and in the remnant deposits of the Hudson River. Recorded levels of PCBs reached more than 500 ppm In the sediment hot spots. ‘and some of the remnant deposits contain average PCB concentrations of more than 50 ppm. While the contaminated sediments are the prImary source of PCB, potential exposures will likely occur only through the atmospheric, aquatic, and blotic pathways. Although the danger of groundwater contamination does not seem to be great, surface water contamination of the Hudson River with PCBs is a potential problem, ES—9 ------- because the river serves as a source of drinking water for various communities. However, PCB monitoring at the Waterford, New York, public water supply has shown no values above the NYSDOH guideline of 1.0 ppb in normally treated drinking water. In fact, the PCB concentration rarely exceeds 0.1 part per billion (ppb) in samples of treated water. At this level of contamination, the incremental risk due to exposures seems to be undetectably small. Recreation on or nearby the Hudson River may cause human exposure to PCB levels. This may occur during swimming, where there is a risk of dermal and oral exposure, or by Illegal fishing, which poses a risk if the contaminated fish are ingested. At present, the only major health threat is posed by human consumption of aquatic organisms. Although the PCB concentration of fish and other organisms is decreasing with time, many individual organisms still contain PCB in excess of the 5 ppm limit set by the Food and Drug Administration. However, a continuation of fishing restrictions, in combination with the publication of advisories which suggest limiting the intake of seafood from the Hudson River, Is a cost—effective remedy. Results Two points must be taken into consideration when assessing the public health risks associated with the remedial alternatives. First, although a large amount of information was gathered in 1977 and 1978 regarding PCBs In the Hudson River, very little of .that Information dealt with PCB concentrations at the receptors. Furthermore, the information which was developed at that time, may not r’efiect current conditions. Some limited Information that is available relative to the receptors (i.e., Waterford water supply) does indicate that the risks associated with the site have decreased. While difficult to precisely delineate, some risk continues to exist at the present time. Second, the alternatives under consideration, including dredging, all contain some element of risk since no alternative can remove all of the PCBs in the Hudson River. Some alternatives may result in a short—term Increase in public health risk during Implementation. The cost— ES—i 0 ------- effective evaluation must consider the relative ability of each alternative to reduce the overall, long—term and short—term risk. Cost—Effective Approach A major objective of this 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 300.68J) as 1 ’. ..the lowest cost alternative that Is technologically feasible and reliable and which effectively mitigates and minimizes damage to and provides adequate protection of public health, welfare, or envlronment. The National Contingency Plan (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 connected with the problem. Criteria to be considered are outlined in Section 300.68(e) of the NCP and include, among many others, 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 may be Included on the list. The third step In the process Is to provide an initial screening of alternatives. The costs, possible adverse effects, relative effectiveness In minimizing threats, and reliability of the methods are reviewed here. The no—action alternative may be included for further evaluation when response actions may cause greater environmental or health damage than no—action responses. No—action alternatives may also be included if It is appropriate relative to the extent of the existing threat or If response actions provide no greater protection. The next step Is a detailed analysis of the remaining alternatIves. This analysis requires a more detailed estimation of costs and engineering implementation and a ES—il ------- 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. The alternatives subjected to the matrix analysis and their estimated costs are given In Table ES—i. The final step requires that the lead agency evaluate the cost—effectiveness of the selected response action against the need to respond to problems with hazardous materials at other sites. Thus, the fund—balancing theme of the NCP generally allows only for the implementation of proven technologies which can be shown to demonstrate a higher level of protection. River Sediments The matrix evaluation process was used to determine the cost—effective solution as provided for by the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Based on the current data available on the PCB problem in the Hudson River, the result of a matrix analyses evaluation with respect to the contaminated sediments In the Hudson River is aflO remedial action.N The results of the analysis were interpreted to mean that the questionable and limited effectiveness of major action alternatives such as hot—spot dredging may not Justify the expenditure of large sums of money in light of the present low impacts and improving conditions associated with the Hudson River PCB problem. The findings of this study appear to be justified. The estimated cost of dredging all 40 previously identified hot spots is approximately $55,000,000 including disposal at a local secure containment site. The estimated cost of dredging Thompson island pool hot spots, the reduced—scale alternative, is approximately $34,000,000 Including disposal. If existing information is accepted as being reliable, we find that these programs will remove only an estimated 22 to 49 percent of the PCB In the Upper Hudson River and only an estimated 19 to 22 percent of all of the PCB in the river, excluding dredge—spoil and remnant—deposit PCB. With full—scale remedial dredging, It could take longer than 46 years for PCBs to be depleted, assuming a constant transport rate and a PCB source of about 350,000 pounds. By ES—12 ------- TABLE ES-i REMEDIAL ALTERNATIVES AND COST COMPARISONS hUDSON RIVER PCB SITE, NEW YORK 1. 2. 3. 4. 5. 8. 7. 8. 9. 10. m 11. 12. c ,3 13. 14. CapItal Costs $289 , 877 . 000 $109,340 000 $249. 787 • 000 $ 15.203,000 $ 54.987.000 $ 34,048.000 $ 120.000* $ 114000 $ 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 $ 42.622.000 $ 36,853.000 O&M Costs $ 0 $ 0 $ 0 $ 1,887,000 $ 5,321,000 $ 5,321,000 $ 3.434.000 $ 3.617.000 $ 1,887,000 $ 3.011.000 $ 1.124.000 $ 1.124,000 $ 0 $ 1,124,000 $ 3,011.000 $ 3,011.000 $ 1.124.000 $ 1,124,000 $ 1,887.000 $ 1.124.000 Total Costs $289. 877 .000 $109,340,000 $249. 787.000 $ 17.090.000 $ 60.308.000 $ 39.369.000 $ 3.434,000 $ 3,731.000 $ 14,781.000 $ 9.928.000 $ 1,496.000 $ 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 RemedIal Alternative Detox. of Sediments with KOHPEO Wet air oxIdation of sediments Incineration of sediments Secure landfill disposal of sediments Dredging of 40 hot spots Reduced scale dredging No remedial action, water supply not treated No remedial action, water supply treated Total removal of all remnant deposits Partial removal of remnant deposits Restricted access to remnant deposits in-place containment of remnant deposits In—situ detoxification of remnant deposits No action on #1. 2. &4/restrict access to #3 & 5 15. PartIal removal/contaminant of remnant deposits 16. Partial removal/restricted access of remnant deposits 17. Partial containment/restricted access to remnant deposits 18. Partial containment/In—situ detoxification of remnant deposits 19. PartIal removal/in—situ detoxification of remnant deposits 20. Partial detoxification/restricted access of remnant deposits ainciudes Proposed Treatability Study ------- the same reasoning, it may take longer than 64 years for PCBs in the Upper Hudson River to be depleted, assuming maintenance dredging continues and removes a constant amount of PCB per year. Even If these objectives are achieved, they may not result In a substantial improvement. Other factors should be considered. Hot—spot dredging Is only a partial solution: some level of risk will continue to exist with or without hot—spot dredging. Furthermore it Is not clear that the majority of the PCB5 which enter the environment each year emanate from hot spots. Since hot spots cover only 8 percent of the total area, It Is entirely possible that cold spots, although less highly contaminated, contribute the majority of dissolved and suspended PCBs due to their far greater surface areas. Past studies have merely defined the extent and possible consequences of the PCB problem and cite dredging as the only alternative available. Few studies have attempted to measure the actual impact of the problem or tried to quantify the actual effectiveness of dredging In reducing these impacts. Six veers after the initiation of PCB studies, this report finds that the actual health Impacts appear to be lower than previously expected, and that environmental contamination Is decreasing much more rapidly than had been anticipated. A review of studies into PCB—environmental interactions and PCB transport has left many questions unanswered but it has indicated that mechanisms are much too complex to conclude that dredging would lead to a measurable amout of Improvement. However, because of the inadequacies of present understanding, it Is recommended that an in—depth health risk assessment be conducted, with future sampling and analysis focusing on PCB levels reachIng human receptors rather than on environmental (e.g., sediment) concentrations. The following study programs are recommended: • Air sampling at residences near dams and rapids on the rivers and near contaminated wetlands. ES—14 ------- • Sampling of private wells which utilize groundwater Immediately adjacent to’ the river. • Sampiing of the public water supplies withdrawing water from the Hudson River. • Sampling of terrestrial vegetation It is also suggested that a study be conducted to access the linkage of aquatic food chains to PCBs which reside in wetlands. Such a study would Involve the sampling of wetland vegetatIon, macro organisms, fish, and sediment. It is further recommended that a treatablllty or water supply replacement assessment be made for the Town of Waterford. The above Investigations are estimated to cost over $500,000. Sampling of sediments in proposed maintenance dredging areas should be performed prior to initiation of dredging. An environmental monitoring program should continue to be implemented. This program would monitor PCB concentrations in fish and river water, and in drinking water supplied by the Hudson River. Remnant Deposits The selected remedial action for the remnant deposits Is in—place containment of remnant deposits. This response action would reduce the potential for direct contact with contaminated sediments and would reduce atmospheric pollution near the remnant sites. A Remedial Investigation should be performed to accurately delineate areas of contamination for covering. Those areas designated to be covered should have approximately 18 to 36 inches of subsoil followed by a 6—inch layer of topsoil placed on them. The cover will then be graded and seeded to minimize erosion. Where needed, bank stabilization will be placed along the riverbank to prevent scour. The estimated cost for the remedial action is approximately $2,300,000, and for the Remedial investigation is $200,000. ES—15 ------- 1.0 INTRODU 11ON 1.1 Background This Remedial Action Master Plan (RAMP) Is prepared in accordance with Subpart F, Sections 300.67 and 300.68 of the Final Rules of the National Contingency Plan (NCR) (47 CFR 137, July 16, 1982). This RAMP is Intended to provide the United States Environmental Protection Agency (EPA) with a basis on which to decide, under the provisions of the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), future actions to be taken with respect to the problems identified at this site. The original Work Assignment issued by EPA was intended to begin the development of a Remedial Action Master Plan (RAMP). Before the RAMP was completed, the Hudson River PCBs Site was placed on the EPA’s National Priorities List, and, as a result, became eligible for the funding of remedial actions. Since the elements required by the Work Assignment are equivalent to those for a feasibility study under CERCLA, the title of this document has been changed to a Feasibility Study. However, the title of RAMP will be used within the text when referring to the document, to eliminate extensive revisions to the document. RAMPs are prepared exclusively from existing information. This information may include sampling data, maps, topographic information, site records, and previous regulatory and remedial actions. Since a significant amount of scientific and engineering information currently exists regarding the problems of PCBs in the Hudson River, this RAMP proceeded beyond the normal objectives of similar documents. Although normal RAMP guidelines were used during its preparation, a major objective of the Hudson River PCB Site RAMP was to reevaluate a previously prepared Environmental Impact Statement (EIS) which had been developed in accordance with the criteria of the National Environmental Policy Act (NEPA) and directed by requirements in Section 116 of the Clean Water Act regarding the relative public Impact of long—term land storage of PCBs. The alternatives studied under the EIS were reevaluated in terms of the criteria established under CERCLA and the NCP. While NEPA requires evaluation in terms 1—1 ------- of the environmental impact of a particular proposal, CERCLA stresses the protection of public health, welfare, and the environment in the most cost— effective manner. 1.2 Setting During a 30—year period ending in 1977, It is estimated that between 887,000 and 1.1 mIllion pounds of PCBs were discharged into the Hudson River from two General Electric (G.E.) capacitor manufacturing plants at Fort Edward and Hudson Falls, New York. Much of the discharged PCBs were adsorbed by the bottom sediments of the river and accumulated behind the Fort Edward Dam. When the dam was removed in 1973 due to its deteriorating condition; a large amount of the PCB—contaminated sediments was released and migrated downstream. The downstream migration was further accelerated during subsequent flood situations, causing PCB—contaminated sediments to move down the entire length of the Hudson River. Based on extensive river—sampling program studies conducted from 1977 to 1978, forty PCB “hot spots” were defined as sediments containing 50 parts per million (ppm) or more of PCBs. In addition, five PCB—contaminated remnant deposits were identified. The remnant deposits are sediment deposifs which were exposed as a result of the removal of the Fort Edward Dam and subsequent drop in the water level of the river. PCB concentrations in two of these exposed remnant deposits average from 5 to 250 ppm. In 1976, the New York State Department of Environmental Conservation (NYSDEC) and General Electric (G.E.) agreed on a $7,000,000 settlement agreement to conduct research studies on PCBs, investigate the extent of PCB contamination in the Hudson River, and develop methods to reduce and remove the threat of continued PCB contamination. As a result of investigations conducted by NYSDEC, a draft Environmental Impact Statement (SEQIS) was prepared in accordance witb the State Environmental Quality Review Act. Recommendations of this study are presented in Table 1—1. 1—2 ------- TABLE 1-1 NYSDEC Recommended Program Full—scale Reduced—Scale Dredging of all 40 hot—spot areas in the river bed with containment in a secure upland site. Design and construction of a secure upland containment site capable of long—term isolation of contaminated material Excavation of two remnant deposits (areas 3 and 5) located above the former Fort Edward Dam site, and removal to the upland containment site. Provision for containment of material from three PCB—contaminated dump sites (old Fort Edward, Fort Miller, and Caputo) should removal be found more suitable than in—place contain- ment. Reduction of the number of hot spots to be dredged, from 40 to approximately 20. Same, except for a reduction in capacity at the containment site. Deletion of remnant deposit removal and upland containment; instead, pro- vision of top dressing and fencing for remnant deposits 3 and 5. Elimination of provision for the con- tainment of PCB—contaminated material from Old Fort Edward, Fort Miller, and Caputo dump sites. Provision for containment of contam- inated materials from three NYSDOT dredge spoil sites (212. 13 and 204 Annex). Destruction of the recovered PCBs at such time as a technologically and economically feasible procedure becomes available. Same Same Provision for funding of research studies related to environmental monitoring. Reduction in the level of funding for research studies. * New York State Department of Environmental Conservation ** New York State Department of Transportation Source: DEIS, 1981 1—3 ------- In September 1980, Congress passed an amendment to the Clean Water Act (CWA) under Title I, 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 it was determined that funds were not first available under Section 115 or 311 of the CWA or from the proposed CERCLA. Congress authorized the EPA to make grants to the New York State Department of Environmental Conservation (NYSDEC) in order to carry out the intent of the Act. The funding authorization which was due to expire on September 30, 1983, has been extended. As a result of this Federal involvement and in accordance with NEPA and the requirements of Section 116 of the Clean Water Act, EPA—Region II issued a Notice of Intent to prepare an Environmental Impact Statement (EIS) ,on January 12, 1981 followed by the publication of a Draft EIS (DEIS) on May 8, 1981. Recommendations of the DEIS are presented in Table 1—2. In August of 1981, due to the State’s development of detailed public health and environmental contingency and mitigation plans, EPA issued a Supplemental Draft EIS (SDEIS). On April 22, 1982, approximately eight months after the publication of the SDEIS, the New York State Hazardous Waste Facility Siting Board rendered its decision to approve the selected site for the disposal of PCB—contaminated sediments. After completing EPA’s required “peer review” process and evaluating the Siting Board Decision, EPA issued the Final EIS on October 8, 1982. The NEPA—EIS 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. At the end of April 1983, a Work Assignment for the Hudson River PCB Site RAMP was issued by EPA to NUS Corporation, the USEPA Zone 1 contractor for implementation of tasks. In June 1983, four Hudson River citizens’ groups filed notice of an intent to sue to require that EPA utilize the funds appropriated under 1-4 ------- TABLE 1-2 EPA—Recommended Program (DEIS) (May 1983) Full—Scale Reduced—Scale Dredging or in—river containment of Reduction of the number of hot spots to all 40 hot—spot areas in the river be dredged or contained In—river. bed with containment In a secure upland site. Design and construction of a secure Same, except for a reduction In capacity upland containment site capable of at the containment site. Indefinite long—term Isolation of contaminated material. Deletion of remnant deposit removal Same and upland containment; instead, provision of secure cap and top dressing, and further bank stabili- zation if necessary. Elimination of provision for the Same containment of PCB—contarninated material from dump sites in the Fort Edward area. Provision-for containment of con— Same taminated materials from three New York State Department of Transpor- tation (NYSDOT) dredge spoil sites (212, 13, and 204 Annex). Provision for dredging and contain— Same ment operational standards and procedures, mitigation measures, monitoring programs, and contingency plans necessary to safeguard public health and agricultural resources. Provision for research studies/environ— Same mental monitoring programs necessary to demonstrate the Improvement in the rate of recovery of the river and storage of contaminated material. Source: DEIS, 1981 1—5 ------- the Clean Water Act Amendment to conduct the proposed demonstration dredging project. In July 1983, the New York State Department of Environmental Conservation filed a similar notice. These legal actions are in progress. In August 1983, the New York State Hazardous Waste Siting Board’s approval of the sediment disposal site was overturned by the New York State Supreme Court. Although the proposed PCB—disposal site is currently unavailable, this RAMP assumes the availability of this site or a similar site in the same vicinity for containment of dredge spoils. 1.3 Scope of Work For the purposes of this study, the Hudson River PCB problem is defined by the PCBs contained within river—bottom sediments and the remnant deposits, as well as the environmental contamination which originated from these sources. PCBs contained within upland dumps are not within the scope of the report. PCBs in dredge spoils are being addressed by NYSDEC and are also not within the scope of this report. The EPA Work Assignment required analysis of all previously prepared studies. It required reevaluation of all alternatives studied through the EIS process. It also required review of new technologies for PCB remediation developed since prepération of the EIS to determine If any-were appropriate to the Hudson River problem. The Work Assignment required determination o f one scheme of remedial actions which would meet the goals and objectives required by CERCLA. This scheme should be sufficiently developed so that design activities can begin upon conclusion of the RAMP. EPA Is expecting development of a work plan for the preparation of plans, specifications, health and safety plans, QAJQC plans, and other plans and documents as needed for implementation. The RAMP must provide a cost estimate for both design activities and remedial actions, and a project schedule for design activities and remedial actions Including appropriate milestones. 1—6 ------- 2.0 THE SITE 2.1 Location The Hudson River, a major transportation route for East Coast products, from its head—waters in Essex County at 43°15’ North latitude and 74°00’ East longitude. traverses 14 counties on its 300—mile journey through eastern New York State. Before emptying into New York Bay, the river flows through 7 locks, and over 15 dams and 3 natural waterfalls. Figure 2—1 shows the general layout of the Hudson River area and the nearby cities. Pollution of the river sediments with polychlorinated biplTenyls (PCBs) began in 1947 at a point approximately 200 river miles upstream of New York City. Contamination of the river originated from two General Electric capacitor manufacturing plants located in the Glens Falls, New York area, approximately three miles upstream of the former dam site at Fort Edward (see Figure 2—1). The river has been arbitrarily divided Into two sections; the upper and the lower Hudson River. The Upper Hudson (study area), where nearly two thirds of PCB contamination is located, covers a 40 river—mile length beginning at Glens Falls and ending at the Federal Dam at Troy (Draft EIS, 1981). Five miles south of Glens Falls is a former dam site at Fort Edward, which, when removed, left significant PCB concentrations termed remnant deposits. Also contained in the Upper Hudson are 40 hot spots” (areas with PCB concentrations of 50 ig/g [ ppm] or greater) which have been identified in this area by the New York State Department of Environmental Conservation (NYSDEC) as containing the majority of contamination located in the Upper Hudson (Phase I Engineering Report, December 1978). The Lower Hudson begins at the dam at Troy and continues downstream 160 river miles to the New York Bay. Hudson River Basin topographic features include fiat lowland areas near the coast and steep rolling hills throughout mld tate New York. The headwaters of the 2—1 ------- ALBANY Co. (Source - Malcolm Pirnie, Sept. 1980) Jhompso Is Darn GLENS FALLS - HUDSON FALLS PROJECT AREA UPPER HUDSON HUDSON RIVER PCB SITE. HUDSON RIVER, NY NOT TO SCALE FIGURE 2-Ia . [ NUS ____CORPORATkJN 0 A HaII Ion Company ALAANY 140 SARATOGA CO. RENSSELAER WAlER VIlE hop Lock MECIIANICvft .L( TROY Lock I RENSSELAER CO. RREN CO. Lock 4 roil Edwoid I Dorn Sill I WASHINGTON CO. FORT EDWARD ------- FIGURE 2-lb PROJECT AREA LOWER HUDSON HUDSON RIVER PCB SITE, HUDSON RIVERJ NY SCALE: 1= P6 MILES NUS _CORPORATD 0 A Hatibu ton Company 0 j (- . c ) 4 OPANSI Co C., U I. S v £ s C *I$TC HIS TI Co S U (P 1* N £ $ C (Source - Malcolm Pirnie Sept. 1980) Co Co N 5 Co ------- Hudson are found in the Adirondack and Catskill Mountain ranges, which are covered by large wilderness and forest areas. In the valleys and lowlands, urban and rural developments prevail. 2.2 Site History Years of production of PCB—containing capacitors and disposal of PCB—laden waste have left more than 500,000 pounds of PCBs in the Hudson River (Malcolm Pirnie, Inc., 1980). This contamination has been traced to two General Electric manufacturing plants that used PCBs in manufacturing capacitors beginning in the late 1940s and ending in 1976. In December of 1972, General Electric applied for a discharge permit, stating that the two plants were dischar ing an average of 30 pounds per day of “chlorinated hydrocarbons,” with a 47.6 pound per day maximum. As of January 1975, General Electric obtained approval to discharge its waste according to the permit request (DEC Technical Paper No. 51). It was not until 1975 that polychlorinated biphenyls were discovered to be a problem in the Hudson River (Malcolm Pirnie, Inc., September 1980). Subsequently, five years of engineering and scientific studies were made, and 40 PCB hot spots were identified in the Hudson River (Draft EIS, 1981). A large portion of the PCB waste in the river was, until 1973, contained behind the Fort Edward Dam at river mile 195. Much of this waste was transported downstream after the removal of the dam in the summer of 1973. Adding to the problem was an April 1976 (100—year) flood, which scoured approximately 260,000 cubic yards of additional material frbm the former dam pool (Malcolm Plrnie, Inc., September 1980). Sediment scouring also occurred In the spring of 1983, during an 80—year—occurrence river level. UntIl 1970, navigational dredging removed approximately 23,000 cubic yards of sediment from the Upper Hudson. This sediment, along with 615,000 cubic yards of dredge between 1974 and 1978, is contaminated with PCBs, and has been placed In seven disposal sites along the river bank (Malcolm Pirnie, Inc., 1980). 2—4 ------- 2.3 Potential Sources of Contamination The problem of PCB5 in the Hudson River was discovered in 1975, when the United States Environmental Protection Agency (EPA) discovered high levels of PCBs in fish taken from the river. Sampling of the river by the NYSDEC produced evidence to implicate two General Electric capacitor manufacturing plants near Glens Falls, New York, as the major contributors of PCBs to the river sediments (DEC Technical Paper No. 58). These plants disposed of approximately 890,000 to 1.1 mIllion pounds of PCBs into the river during a 30—year period. In addition to the in— river disposal, General Electric also landfUled transformers containing PCBs, adding approximately 528,000 to 745,000 pounds to The environment (Malcolm Pirnie, Inc., 1978). The continued presence of PCBs in the Hudson River basin leads to a possibility of more widespread contamination through contaminant migration. The sources that continue to contribute PCB waste are (Weston, 1978): • Sediment exposed or released upon the removal of the Fort Edward Dam • Disposal areas for dredged bottom sediment contaminated with PCBs • Landfills containing PCB liquids and impregnated solids • Wastes containing PCBs unrelated to the General Electric plants In the summer of 1973, the Fort Edward Dam was removed due to its advanced state of deterioration. Sediments that had collected behind the dam became exposed due to the lowering of the river. Portions were subsequently scoured by high river flows and transported down river. The exposed areas, known as remnant deposit areas, have high levels of PCB contamination. These areas are subject to erosion by the river, surface water runoff, or wind (only 2 of 5 remnant deposit areas have had bank stabilIzation work performed), as they have little or no vegetative cover on them. The sediments that have been exposed to the higher river flows have been transported down river, with the majority of the contamination remaining in the 2—5 ------- Upper Hudson region (Malcolm Pirnie, Inc., 1978). Sampling done in 1975—77 has delineated 40 hot spots where high levels of PCBs exist and could potentially move downstream, further contaminating the river. Because of the increased amount of sediments in the river due to the removal of the dam, it became necessary to dredge some areas that were left unnavigable when large volumes of sediment were deposited in the river channel. Approximately 790,000 cubic yards of material were deposited In the channel near Rogers Island. During 1974 and 1975 the New York Department of Transportation (DOT) removed approximately two thirds of this material and placed the PCB— contaminated spoils in five riverside disposal sites. In 1977 and 1978 DOT removed additional deposits and increased the number of disposal sites by two. These disposal sites contain an estimated 103,000 to 160,000 pounds of PCB5, approximately 9 percent of the river basin total (Malcolm Pirnie, Inc., 1978). While disposing of wastes In the river, General Electric also landfilled its old transformers which contained PCBs as a dielectric fluid. The amount of PCB5 landfilled is approximately 528,000 — 745,000 pounds, or 40 percent of the basin total. The security and containment controls at these sites are minimal in some cases, thus leading to PCB transport due to groundwater flow and leaching, or erosional effects from surface water drainage (Weston, 1978). Table 2—1 shows the estimated overall distribution of PCBs in the Hudson River Basin. PCB contamination from sources other than the two. General Electric plants Is unknown. No report of additional PCB contaminant sources has been made to date. 2.4 Response Actions to Date The following Is a list of response actions to date for the Hudson River. Included are physical, remedial, and legal actions as well as river sampling and testing. 2—6 ------- TABLE 2-1 ESTIMATED MASS OF PCB IN ThE HUDSON RIVER BASIN ASSOCIATED WITH GENERAL ELECTRIC PLANTS NEAR FORT EDWARD. N.Y. UPPER HUDSON RIVER BASIN Remnant Deposits Thompson Island Pool Sediments 2 Hot Spots Cold Areas Remaining Upper Hudson Pools Hot Spots Cold Areas Subtotal, Upper Hudson River Sediments Only Hot Spots Cold Areas Dredge Spoils Dumps 3 Subtotal, Upper Hudson River Basin Only LOWER HUDSON RIVER BASIN Sediments Dredged Washed Out To Sea 46,820—108,600 pounds 1 97,700—105,800 22,000—30,900 60,600—64.100 101.400—146,400 158,300—169,900 123 400—177 ,300 281,700—347,200 103,455—160,000 528,000—745,000 959,975-1,360,800 169 ,000—200, 000 86,000 200,000 TOTAL PCB 1,414,975—1,837,930 1 Remnant Deposit Totals do not include estimates for area 3A. 2 Thompson Island Pool totals include estimates for sediments above Lock 7. 3 Includes PCBs in the Moreau Facility. Sources: Bopp et al. 1978; Hetling et al., 1978; Tofflemire and Quinn, 1979; Malcolm Pirnie, 1980. 2—7 ------- Date Response Action 1950—1974 Navigational dredging removes an average of 23,000 yards of sediment per year in Fort Edward Area. 1974 (Apr.—Dec.) Dredging of 175,000 yd 3 of debris from main river channel at and downstream of Lock 7 by DOT maintenance forces. Dredging of 85,000 yd 3 of debris and sediments from Fort Edward Terminal Channel betwen Lock 7 and o & H Railroad Bridge by DOT maintenance forces. 1975 (Jan., May—Nov.) New York State Department of Transportation (DOT) performed maintenance dredging, which included removal of debris and sediment that accumulated in the barge canal system. July 974—June 1975 Removal of 180,000 yd 3 of debris and sediment from Fort Edward Terminal Channel upstream of D & H Railroad Bridge and northerly tip of Ro 9 ers Island and excavation of sediment trap of 70,000 yd capacity. Oct 1974—Nov. 1975 Placement of Rock from cribs on banks of remnant pool deposils 3 and 4. Placement of dumped rock at remnant deposit 5. 1975 PCB levels in some Hudson River fish were found to exceed Food and Drug Administration levels (5 ppm maximum) during USEPA fish sampling. May—Nov. 1975 Removal of 13,000 ‘jd 3 of debris and sediment from west channel near Rogers Island. September 8, 1975 Administrative proceedings were begun charging General Electric with the disposal of PCBs into the Hudson River. September 8, 1976 Settlement agreed upon between the NYSDEC and G.E. for 7 million dollars to investigate the PCB problem In the Hudson River. 1976 New York State Department of Health certified that a human health problem existed due to consumption of fish taken from certain areas of the Hudson River. Fishing was banned in the Upper Hudson from the Troy Dam north to Fort Edward, N.Y. 2—8 ------- Date Response Action 1976 con’t. Dredging of 35,000 yci 3 of sediment near bouy 212 by DOT maintenance forces. 1977 As a result of the settlement with the NYSDEC, General Electric ceased all discharge of PCBs. Fall 77 Spring 78 Dredging of 170,000 yd 3 of sediment from channel near Rodgers Island and containment of these sediments in New Moreau Site. Additional bank stabilization measures at Site 3. August—December Weston Environmental Consultants conducted a surface 1977 mapping of 12 PCB disposal site6. Weston concurrently conducted initial soil, water, and blotic sampling. October 1978 Remnant deposit 3A (14,000 cubic yards) was excavated and transported to the New Moreau Site. September 1980 Congress passed an amendment to the Clean Water Act under Title I, Section 116(a) and (b) authorizing the Hudson River PCB Reclamation Demonstration Project. May 1981 USEPA prepared a Draft Environmental Impact Statement (EIS) addressing the dredging demonstration project. August 1981 A supplement to the May EIS was prepared by the EPA. This Supplemental EIS included additional material omitted in the Draft September 16, 1982 The EPA conducted a Mitre model ranking of the Hudson River. As a result, the river was given a score of 54.66. December 1982 The Final EIS was completed by the EPA. )ncluded in this report were updates and comments on the earlier Draft and Supplemental EISs. December 30, 1982 Funding for the project became available through the Comprehensive Environmental Response, Compen- sation, and Liability Act (CERCLA, or Superfund). 2—9 ------- 3.0 ENVIRONMENTAL SETTiNG 3.1 Landforms The Hudson River Basin lies In the Valley and Ridge Physiographic Province. Pt covers 13,365 square miles or 27 percent of the State of New York (Malcolm Pirnie, Inc., 1980) , Ninety —fIve percent of the basin is in New York State, but Its heaciwaters include small portions of Vermont Massachusetts, and Connecticut. The basin topography Includes steep and rolling hills, undulating land, and some mountainous areas. Landscape varies from wilderness in the Catskill and Adirondack Mountains to agricultural areas in the valleys (NYSDEC, 1979a). The Hudson River itself is located in the Hudson—Champlain lowlands of the Valley and Ridge Physiographic Province. The lowlands are composed of a plain ranging from 1/4 to 2—1/2 miles in width that was once pro—glacial Lake Albany. Elevation of the lowland areas ranges from 100 feet to 400 feet above mean sea level. 3.2 Surface Waters The Hudson River from New York Harbor to Albany Is a tidal estuary of 150 miles in length. From the Federal Darn at Troy north to Fort Edward are eight dams with locks to accommodate New York barge traffic. The locks and dams in this area form a series of pools throughout this reach. From Fort Edward north to the Hudson—Sacandaga River junction are seven dams and three natural waterfalls that are used to generate hydroelectric power (Malcolm Pirnie, Inc., 1980). Several reservoirs above Glens Falls are used to regulate flows in the Upper Hudson. These reservoirs are Indian Lake, Piseco Lake, Spier Falls Reservoir, Sherman Island Reservoir, and Sacandaga Reservoir. The Sacandaga Reservoir is the largest with 760,000 acre-feet of storage (NYSDEC, 1979). Reservoir flow is regulated during low flows to maintain navigation, water quality, and hydroelectric power generation. During high flows, the reservoir is regulated to prevent excessive flooding. Water is released from the Sacandaga Reservoir to keep a minimum flow of 300 cubic feet per second (cfs) for maintaining navigation and 3 —1 ------- power generation. A minimum depth of 12 feet is also maintained for barge navigation (Malcolm Pirnie, Inc., 1980). The major tributaries to the Hudson River from New York Harbor in the south, to Troy in the north, are as follows: the Croton River, Moodna Creek, Fishkill Creek, Wappinger Creek, Rondout Creek, Esopus Creek, Roeliff—Hansen Kill, Catskill Creek, Kinderhook Creek, and the Normans Kill. The major tributaries north of Troy are the Mohawk River, Hoosic River, Fish Creek, Batten Kill, Champlain Canal, Schroon River, and Indian River. The drainage area of the Hudson River at Fort Edward is 2,818 square miles and increases at the Federal Dam at Troy to 8,090 square miles, including the additional 3,450—square—mile drainage of the Mohawk River. 33 Geology and Soils The area of geologic study will be limited to the stretch of the Hudson River from Troy north to Hudson Falls encompassing the eastern quarter of Saratoga County, northwestern Rensselaer County, and southwestern Washington County. Geologic units in the study area are composed of both consolidated and unconsolidated deposits. Ordovician shaIes are the predominate bedrock, whereas Pleistocene glacial deposits comprise the unconsolidated surficial geology. 3.3.1 Bedrock Geology The major bedrock formations in the study area are the Snake Hill Formation (shale), Normanskill Shale, Beekmantown Limestone, and the Schodack Formation (shale). The bedrock formations have a general northeast—southwest strike and southeasterly dip. These formations, with the exception of the Snake Hill, are not indigenous to the study area but belong to a series of formations deposited in a trough farther to the east and moved to their present position by folding and faulting along a multiple of thrust—fault planes. The folding and faulting created numerous fractures and fissures which control the movement of groundwater (Cushman. 1950). Figure 3—1 depicts a stratigraphic section of bedrock within the study area. 3—2 ------- MOST RECENT FORMATiON. LOCATED IN LOW-LYING AREAS OF HUDSON RIVER VALLEY. CONSIS TS OF DARK GRAY TO BLACK, BLUISH AND 6L CK CARBONACEOUS BANDS. A MEMBER OF THE TACONIC SEQUENCE OF ROCKS COM- PRISING THE HILLY AND MOUNTAINOUS AREAS OF WEST- ERN NSS AER AND WASHINGTON COUNTIES. SEPARATE FROM THE SNAKE HILL FORMATION TO TIE WEST BY AN EASTWARD DIPPtIG THRUST FAULX PLANE. CONSISTS OF A DARK-GREEN TO BLACK AGRILLACEOUS SHALE CON- TAINING WHITE - WEATHERING CALCAREOUS CHERT BEDS. UNDERLIES THE TACONLC SEQUENCE OF ROCKS AND OVERUES SNAKE HILL FORMATION AWNG AN EASVNAR DIPPING THRUST FAULT PLANE. CONS 1STS OF MASSIVE COARSE TO FiNE - .GRAINED DOLOMITIC LIMESTONE. A UNIT OF THE 1 ONIC SEQUENCE OF ROCKS. CONSIST OF A BRICK - RED WEATHERU G GRIT, A CALCARECUS SANC STONE, A THIN - 9EDD LIMESTONE, AND RED AND PUR PLE SHALE. FIGURE 3-I STRATIGRAPHIC SECTION - BEDROCK HUDSON RIVER PCB SITE, HUDSON RIVER, NY NOT TO SCALE NUE _____ ccRPc AflcN 0 A HailiburtonCompan’ 8 0 8 0 0 8 3—3 ------- The Snake Hill Formation is the most recent bedrock formation in the study area (Middle Ordovician). The Snake Hill is located in the low—lying areas of the Hudson River Valley and consists of dark, gray to black, bluish and greenish shales with thin sandy and black carbonaceous bands (Cushman, 1950). Beds in the Snake Hill are severely crumbled and contorted, and cut by cleavage planes as well as smoothed slip planes that give it a glazed appearance. In the vicinity of Hudson Falls, the Snake Hill lies almost flat and undisturbed, with a thickness near 600 feet (Cushman, 1953). The Normanskill Shale (Middle Ordovician) is a member of the Taconic sequence of rocks that comprise the hilly and mountainous areas of western Rensselaer and Washington Counties. It is separated from the Snake Hill Formation to the west by an eastward dipping thrust fault plane. It consists of a dark—green to black argillaceous shale containing white—weathering, calcareous chert beds (Cushman, 1950). The Normanskill is highly folded and has a total thickness of approximately 1000 feet (Cushman, 1953). The Beekmantown Limestone outcrops near the town of Middle Falls, underlies the Taconic sequence of rocks, and overlies the Snake Hill Formation along an eastward dipping thrust—fault plane. It forms a small ridge running north to south on the western foothills of the Taconic mountainous sequence of rocks. The Beekmantown Limestone also occurs north and northwest of Hudson Falls in the low—lying areas. It consists of massive, coarse to fine—grained dolomitic limestone with an average thickness of 900 feet and is Cambrian—Ordovician in age (Cushman, 1953). The Schodack Formation is also a unit of the Taconic sequence of rocks and occupies a large part of the Taconic mountainous areas. The formation was formed during the Lower Cambrian Period and is composed of greenish—gray, fine—grained, siliceous shale presenting a highly folded appearance; locally it includes a brick—red weathering grit, a calcareous sandstone, a thin—bedded limestone, and red and purple shale. Total thickness of the Schodack Formation is believed to be 1000 feet (Cushman, 1950). 3—4 ------- 3.32 Surflcial Geology In most places within the study area, the bedrock Is overlain by unconsolidated glacial materials and more recent materials that range in depth from a few inches to more than 200 feet. The unconsolidated sediments within the study area are glacial till, glacial outwash, lacustrine deposits, recent alluvium, and modern dredge spoUs. The glacial deposits of the study area are the result of the Wisconsin age glacial advancement, the most recent advance of the Pleistocene Epoch. Till deposits occupy approximately 10 percent of the study érea. Glacial till Is a highly variable assortment of rock material that ranges in size from clay—size particles to rock fragments and boulders. The till usually occurs as ground moraines or drumlins of thickness varying from 30 to 100 feet (Cushman, 1950). Generally, the till is not stratified but local deposits of sand, gravel, silt, or clay within the till mass do occur as a result of local sorting. Deep till deposits in this area tend to be more dense than shallow deposits which have undergone more weathering (Malcolm Pirnie, Inc.. 1978). Glacial outwash deposits cover approximately a quarter of the study area. These deposits consist of sand and gravel left by glacial meltwater. They show a fair degree of sorting and frequently show cross—bedding and evidence of scour and fill (Cushman, 1950). Outwash Is found on such landforms as outwash terraces, eskers, valley trains, kames, deltas, and outwash fans. These deposits are generally younger than ‘(and commonly rest on) till. Valley—filled deposits were formed in local lakes or stream channels where spillways which were controlled by ice or glacial debris were located. The thickness of the deposits is influenced by the shape and bedrock of the valleys. These highly variable sediments are usually stratified, consisting of gravel, coarse through fine sand, and clay. Deltaic deposits are outwash formations that were built at points where streams laden with large rock debris entered the still waters of proglacial Lake Albany and spread out 3—5 ------- into a fan shape. Deltaic deposits are composed of material ranging in size from coarse gravel to fine sand and silt (Malcolm Pirnie, Inc., 1978). Glacial lacustrine sediments comprise over half of the study area. These sediments were deposited on the bottom of proglacial Lake Albany, which extended from Rensselaer County to Essex County some 10 to 15 thousand years ago. These clays were laid down in the quiet water of the glacial lake and were exposed as flat terraces or bottom lands when the lake drained, near the end of the Pleistocene Epoch. The formations occur along the Hudson River as terraces, covering flat to gently rolling valley floors. The lower beds are predominantly varved, fine— grained, bluish clays grading into yellowish—red silts (Malcolm Pirnie, Inc.. 1978). Recent river deposits or alluvium consist of various sediments deposited along streams. Alluvial deposits are compo5ed of a veneer of silt, clay, sand, and some gravel that was laid down by streams (Cushman, 1950). These deposits are usually located on the flood plains within half a mile of the banks of the Hudson River and tributaries (Malcolm Pirnie, Inc., 1978). Canal—dredging spoils deposited along the Hudson River constitute the man—made land encountered within the study area. These deposits are generally of a coarse nature, consisting of quartz—feldspar sands, cinders, and shale cobbles mixed with wood fragments of all sizes (sawdust to pieces several feet in length) (Malcolm Pirnie, Inc., 1978). Figure 3—2 depIcts a stratigraphic section of unconsolidated sediments within the study area. Figures 3—3 and 3—4 depict surficial geology maps of the Hudson River In the northeastern region of Saratoga County and the southwestern region of Washington County, respectively. 3—6 ------- 0’ o• ..‘:.. .•... . . s.: •.f j.” . ...: tj.e. : 2 CANAL DREDGE SPOILS: CONSITUTES THE MAN MADE LAND ENCOUNTERED WITHIN THE STUDY AREA. CONSISTS OF QUARTZ-FELDSPAR SANDS, CINDERS, SHALE COBBLES MIXED WITH WOOD FRAGMENTS OF ALL SIZES. ALLUVIAL DEPOSITS NORMALLY LOCATED ON THE FLOOD PLAINS WITHIN A HALF MILE OF THE RIVER BANKS. CONSISTS OF CLAY, SILT, SAND, AND SOME GRAVEL. GLACIAL OUT WASH DEPOSITS: COVER APPROXIMATELY 1/4 OF THE STUDY AREA. CONSISTS OF SAND AND GRAVEL DEPOSiTED BY GLACIAL MELTWATER. TILL DEPOSITS: COVER APPROXIMATELY I/tO OF THE STUDY AREA CONSISTS OF A HIGHLY VARIABLE ASSORTMENT OF ROCK MATERIAL RANGING IN SIZE FROM CLAY-SIZE PARTICLES TO ROCK FRAGMENTS AND BOULDERS. GLACIAL LACUSTRINE SEDIMENTS: COMPRISE OVER 1/2 OF THE STUDY AREA. CONSISTS OF BLUISH CLAYS AND YELLOWISH-RED SILT. -e 200’ STR flGRAPHIC UNCONSOLiDATED SECTION HUDSON RIVER MATERIAL PCB SITE, HUDSON RIVER, NY FiGURE 3-2 NOT TO SCALE ___CORPCRAflON 0 A Halliburton Company 3—7 ------- SURFICIAL GEOLOGY SCALE OF SARATOGA COUNTY LEGEND SAND AND GRAVEL CHIEFLY SAND BUT INCLUDES SOME GRAVEL. SMALL ISOLATED DEPOSITS NOT SHOWN. YIELDS MODERATE TO LARGE SUPPLIES OF WATER. CLAY AND SILT YIELDS WATER. MAINLY TO LARGE- DIAMETER WELLS. TILL CHIEFLY AN UNSORTED MIXTURE OF ROCK FRAGMENTS RANGING IN DIA- METER FROM SMALL FRACTIONS OP AN INCH TO SEVERAL FEET. INCLUDE ThIN SAND LENSES IN PLACES. BED- ROCK OUTCROPS ARE COMMON BUT ARE NOT SHOWN. YIELDS SMALL SUPPLIES OF WATER TO LARGE- DIAMETER WELLS. (REF’ R.C.HEATH, ET AL, 1963) FIGURE 3-3 NUS cOR RAnON 0 A Halliburton Company I I/ o I 2 I12S HUDSON RIVER PCB SITE, HUDSON RIVER, NY 3-8 ------- LEGEND FLOOD-PLAIN AND RI VER - TERRACE AU.UVIUN. FINE SAND AND SILT. Fm-flu LACUSTRINE CLAY; VARVED CLAY AND SILT Z DELTA DEPOSITS; FINE SRAVEL, SAND O AND CLAYEY SAND. U) w 0. 4 z I - 4 a Z :-:- - -:-±J ft-: ---: -- : acu n - ffl : : :- :- -: ) -:--:-:-:- € - th :-: __ - !- - - - k-:- -:-; - -- t :g /4=:: - ___ . -:-: -:-- J: ::-:-:- - - - : -:- --. _ -:- -- - --: --i i — .rij jw - $•• 9 7 FIGURE 3-4 SURF1CIAL GEOLOGY OF WASHINGTON COUNTY HUDSON RIVER PCB SITE, HUDSON RIVER, NY - JLJS - CORPORATiON 0 A Halliburton Company OUTWASH; FINE GRAVEL AND SAND TILL AND BEDROCK OUTCROP. (REF’ CUSHUAN,I9 3.) SCALE I ZNI I .L3 $ I JLI 9 - CO U NT ’? LI N ( N S S £ LA ------- 3.3.3 Soils Most of the soils within the study area have been formed in glacial drift that was deposited by the Wisconsin advance of the Pleistocene Epoch. Additional soils have been formed in more recent deposits of alluvium or dredge spoil. Soils developed in till over bedrock are of minor occurrence within the study area. Depth to bedrock in these soils is shallow, ranging from 1 to 3.5 feet. These soils are usually found on undulating to hilly uplands. The drainage of these soils ranges from moderately well drained to somewhat excessively drained. Fragipan, a dense subsurface horizon which is low in organics and permeability that sometimes causes perching of the groundwater table, is often encountered in ‘these soils (Malcolm Pirnie, Inc.. 1978). Soils in glaciolacustrine sediments on lake plains and valleys are extensive within the study area. These soils are found on nearly level, depressional, or very steep slopes. Glaciolacustrine soils are generally deep, 3.5 feet or more, and have variable drainage classes, ranging from somewhat poorly drained to well drained (Malcolm Pirnie, Inc., 1978). Wetness increases with depth in these clayey and silty deposits. Water contents as high as 60—70 percent have been reported (SCS, 1975). The soils formed on plains, terraces, kames, eskers, and glacial outwash deposits in the valley are generally deep (6 feet or more), excessively drained, and coarse textured gravelly soils. Many of these soils are underlain by silt and clay lenses which impede their drainage. Soils that are formed in recent river or alluvial deposits are 4 feet deep or more, and medium textured (high in silt and fine sand), with variable drainage classes (very poorly drained to well drained). These soils are subject to flooding except where the flow is regulated (Malcolm Pirnie, Inc., 1978). 3—10 ------- 3.4 Groundwater Groundwater aquifers within the study area can be classified in either of two catagories: Ordovician and Cambrian consolidated rocks or Pleistocene unconsolidated sediments. The consolidated rocks generally have low effective primary porosities. In many consolidated formations, the presence of joints. fractures, and faults Increases formation permeability greatly. The Pleistocene unconsolidated sediments generally yield greater amounts of water than the consolidated rocks due to high permeabilities. The consolidated formations that yield noticeable amounts of water within the study area are the Snake Hill Formation, Beekmantown Limestone, Normanskill Shale, and the Schodack Formation. The Snake Hill Formation is the highest water—bearing consolidated formation within the study area. It is generally crumbled and contorted and cut by cleavage planes. Occasional sandy limestone strata within the Snake Hill help yield water at an average of 16 gallons per minute (gpm). Water yields are highly variable in these shales since permeability is dependent upon joints, fractures, and faults. The Beekmantown Limestone is generally a good source of water, with average well yields of 12.7 gpm. Joints are the chief water bearers in the Beekmantown. The Normanskill and Schodack Formations have average groundwater yields of 6 and 5 gpm, respectively. The yields within these formations are dictated by Joints, and by cleavage and bedding plane fractures (Cushman. 1950, 1953; Malcolm Pirnie, Inc., 1983). The Pleistocene unconsolidated sediments yield groundwater at various rates. The sediments that yield considerable amounts of water are glacial outwash and till. Other sediments that yield small amounts of water ar lacustrine and alluvial deposits. Glacial outwash deposits are the most productive water bearers in the study area. These high—permeability, stratified sands and gravels have water yields ranging from 15 gpm for unscreened wells to 300 gpm for screened and developed wells. Deltas are the most productive water—bearing glacial outwash deposits (Malcolm Pirnie, Inc., 1983). 3—11 ------- Low porosity till yields water very slowly. The estimated average yield of these deposits is from 1 to 2 gpm (Malcolm Pirnie. Inc., 1983). The more productive wells obtain their water from thin sand lenses within the deposit and are suitable for domestic use. Till deposits are usually found on hillsides, highlands, and in small localized areas in the river valleys. Other types of aquifers that yield small quantities of water in the study area are lacustrine deposits and alluvial deposits. Lacustrine deposits of clay and silt yield water very slowly and in negligible quantities. Alluvial deposits are not coarse enough or of sufficient thickness to be important sources of groundwater. Shallow wells that obtain water from the alluvium probably intersect lenses of sand. The aquifers within the study area are generally bordered by or underlain by relatively impermeable silt, clay, till, shale, or crystalline bedrock. Therefore, migration from aquifer to aquifer is minimal. Measurements of streamflow in the area indicate that most of the streams are effluent. Accordingly, groundwater recharge is most likely to occur by way of precipitation, which readily enters the aquifers through the permeable surface. Average annual precipitation in the Glens Falls area is about 40 inches. Of this, 10 inches is estimated to recharge the sand aquifers from mid—fall to mid—spring (Glese, 1970). The remaining precipitation is probably direct runoff to surface water. 3.5 Climate and Meteorology The average monthly temperature and precipitation figures for Albany County Airport, Albany, New York, for 1981 are shown In Table 3—1. The climate at Albany is primarily continental in character but is subjected to some modification from the maritime climate which prevails in the extreme southeastern portion of New York State. The moderating effect on temperatures is more pronounced during the warmer months than in the cold winter season, when outbursts of cold air sweep down from Canada with greater vigor than at other times of the year. In the warmer portion of the year, temperatures rise, rapidly 3—12 ------- TABLE 3-1 CUMATE AND METEOROLOGY Albany County Airport The average monthly temperature arid precipitation figures for Albany County Airport, Albany, New York. for 1981 are shown below. Average Monthly Average Monthly Month Temperature (°F) Rainfall (inches ) January 14.0 0.59 February 33.1 5.02 March 34.7 0.26 Apri l 48.1 1.99 May 58.9 2.44 June 66.7 2.78 July 69.3 3.50 August 68.5 1.76 September 58.8 3.45 October 44.8 3.55 November 37.7 1.56 December 25.7 3.54 Yearly Average 46.7 Total 30.44 3—13 ------- during the daytime to moderate levels. As a rule, temperatures fall rapidly after sunset so that the nights are relatively cool. Occasionally the area experiences extended periods of oppressive heat up to a week or more in duration. The highest temperature of record is 104°F, but since 1874, 100°F temperatures have been recorded on only 15 days (National Oceanic and Atmosphere Administration (NOAA), 1981). Winters are usually cold and occasionally severe. Maximum temperatures during the winter months often fall below freezing and nighttime low temperatures frequently drop to 10°F or lower. Subzero temperatures occur infrequently, about a dozen times a year. Yearly snowfall in the area is highly variable and some of the higher elevations experience accumulations in excess of 75 inches. Precipitation is sufficient to serve the regional economy in most years, and only occasionally do periods of drought become an environmental threat. A considerable portion of the rainfall in the warmer months Is from showers associated with thunderstorms, but hail is usually not of any consequence (NOAA, 1981). Surface water runoff of the Hudson Basin varies from about 19 inches to 24.5 inches, with the remainder of the precipitation returning to the atmosphere through evapotranspiration (NYSDEC, 1979). 3.6 Land Use The Hudson River Basin has a total population of 2.5 million. The basin borders the New York metropolitan area, which has an approximate population of 12 million (NYSDEC, 1979). Albany, the largest city in New York along the Hudson, has an approximate population of 100,000. Cities with populations greater than 25,000 In New York are Newburgh, Poughkeepsie, and Troy (Rand McNally, 1982).The major industries of the Hudson River Basin are agricultural, service, and manufacturing. Dairy farming and apple and pear orchards comprise a large part of the agricultural development. Petroleum refineries, grain bins, and paper mills are located at various sites along the river. Significant portions of the Northern Hudson River Basin lie in the Adirondack Park. while portions of the southcentral basin are in the Catskill Park. Camping, hiking, 3—14 ------- and skiing are some of the forms of recreational activities available within the basin. Several furbearers are abundant in the river valley. Mink, otter, and muskrat are valuable fur—bearing species. Common game species Include deer, eastern cottontail rabbit, gray squirrel, and raccoon, as well as game birds, such as ruffed grouse, pheasant, and woodcock. Bears are also occasionally noted. The bobcat and coyote are much less common species In the Hudson River Basin (NYSDEC, no date). Birdlife in the Hudson River Valley Is abundant and Includes many common birds of the woodlands and open fields, The wild turkey, a game species, has been successfully reintroduced in New York and Is found in upland areas along the Hudson River estuary (Malcolm Plrnie, Inc., 1983). Several species of birds and plants are considered endangered by New York State andlor the U.S. Fish and WIldlife Service. Those bird species are the bald eagle, peregrine falcon, and osprey. The endangered plant species include heartleaf plantaIn ( Plantaqo cordataj , Nuttall’s Micranthemum ( Micranthemurn micran— themoides) , bur marigold ( Bidens bidentoldes ) and golden club ( Qj ontium apuaticum ) (Malcolm Pirnie, Inc., 1983). 3.7 Water Use 3.7.1 Surface Water Use The Hudson River has 2 million acre—feet of storage, most of which Is In the upper basin. Various primary uses Include hydroelectric power, public supplies, navigation, water recreation, and flood damage reduction. The stretch of the Upper Hudson River from the Mohawk—Hudson Junction north to the Sacandaga—Hudson Junction Is the greatest hydroelectric—producing area in the basin. A total of ten hydroelectric plants are located on the main—stem Hudson River, with most of these being on the Upper Hudson. 3—15 ------- Several communities obtain drinking water from the Hudson River, including the City of Poughkeepsie, the Highland Water District, the Port Ewen Water District. the Village of Rhinebeck, and the Village of Waterford (Malcolm Pirnie, Inc., 1980). A water intake located at Chelsea, north of Beacon, New York, may be used to supplement New York City water supplies during periods of drought. The Village of Waterford is the northernmost community that receives its water supply directly from the Hudson downstream from the General Electric outlets. The intake is located on the west side of the Hudson, at the northern end of the village limits. The daily withdrawal is approximately one million gallons. The water is treated by coagulation, flocculation, and settling, followed by rapid filtration, and chlorination (Malcolm Pirnie, Inc., 1978). - The Hudson River itself is a major industrial transportation route. Total tonnage of commerce on the Hudson River waterway has declined over the past 21 years of record, ranging from a high of 42,421,533 tons in 1957 to a low of 28,220,192 tons in 1977 (Corps of Engineers, 1972, 1977; Malcolm Pirnie, Inc., 1983). The cargoes consisted almost entirely of petroleum products enroute to communities on the Champlain Canal and Lake Champlain. The shipping season usually begins in late April and continues until early December (Malcolm Pirnie, Inc., 1978). The Hudson River supports a variety of water—based recreattonal activities, which include sport fishing, waterfowl hunting, fur trapping, swimming. and boating. The recreational fishery of the mid—Hudson River, from the Federal Dam at Troy to Poughkeepsie, includes largemouth and smailmouth bass, brown bullhead, yellow perch, walieye, blueback herring, alewife, rainbow smelt, sunfish, and black crappie. Catches of striped bass and American shad have also been reported as far upriver as Troy Dam. Sheppard (1976) estimates fishing activity in this segment to be about 30,000 angler—days per year. The fishery of the lower Hudson south of Poughkeepsie includes striped bass, American eel, Atlantic tomcod, blue fish, white perch, white catfish, winter and summer flounder, blueback herring, and alewife. Important aquatic invertebrates include the freshwater mussel and the blue crab, the latter an important recreational species harvested from the shallow waters of Peekskill Bay. Based on aerial surveys in 1972 through 1974, the lower fishery 3—16 ------- supports an estimated 20,165 angler—days annually (Sheppard, 1976). As a spawning ground for striped bass and a nursery for bluefish, the Hudson also contributes to the marine fishery. Sheppard also estimates that the striped bass fishery supports 1,417,000 angler—days annually with an economic value of more than $28 million (Malcolm Pirnie, Inc., 1983). The shortnose sturgeon, which Is an endangered fish species, exists In the Hudson River estuary. This reach of the river is utilized as a spawning ground, a major overwinter area, a nursery area for young of the year fish, and as a summer feeding ground. The shortnose sturgeon is very susceptible to PCB contamination due to its occurrence and spawning in the highly polluted area located just below the Federal Dam at Trov (DEIS, 1981). The flood control reservoirs within the Hudson River Basin are used to control river flows during flood or drought conditions in order to maintain barge navigation and hydroelectric power generation. Some homes and farms along the Hudson River also use the river as a supplemental water supply for watering lawns and gardens, and for irrigating crops. 3.7.2 Groundwater Use Several municipalities, industries, and private Individuals obtain water from wells located adjacent to the Hudson River. The Town of Stiliwater operates four wells, and Green Island draws water from infiltration galleries located on an Island in the Upper Hudson River (Malcolm Pirnie, Inc., 1980). The amount of water drawn exclusively for industrial use is small and restricted mainly to light Industries such as creameries and garages. Most of the heavy Industry in the area is situated in or near the larger towns and cities and utilize municipal water supplies. In areas not served by a public water system, domestic water supplies are obtained almost exclusively from wells and springs. The domestic uses of water include drinking, cooking, washing, and sewage disposal, arid these needs are normally met by dug or drilled wells of low yield. Water for cattle and other farm animals is also obtained by the same method, and in many cases where the number of stock to be cared for 3—17 ------- is small, one well may suffice for both the farm and the household. The average consumption from this type of well is generally less than 500 gallons per day (Cushman, 1950). 3—18 ------- 4.0 ENVIRONMENTAL CONCENTRATIONS 4.1 Concentrations, Distribution, and Trends PCBs are water insoluble compounds which have a pronounced tendency to adsorb onto fine particulate matter. These chemicals have an especially high affinity for carbon—rich materials such as activated carbon, humus, and soil organic matter. Because of this property, a large portion of the PCBs in the General Electric discharges adhered to organic—rich sediments, particularly those that accumulated behind the Fort Edward Dam. Between 1974 and 1977, approximately 1 1 million cubic yards of PCB—contaminated sediments were released to the river during high flows following the removal of the dam in 1973. Since the court mandated elimination of PCBs from the 0. E. discharges in 1977, these contaminated sediments and the exposed deposits in the former dam pool are believed to be the primary source of PCBs in the Hudson River environment. This section presents major conclusions of five years of scientific and engineering studies on PCB contamination in sediments, water, air, and biota of the Hudson River Basin. 4.1.1 Sediments 4.1.1.1 Remnant Sediment Deposits The removal of the Fort Edward Dam left 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 Figure 4—1. Approximately 850,000 cubic yards of this material was scoured by high flows between July 1973 and July 1974 (Malcolm Pirnie, Inc., 1975). Another 260,000 cubic yards of sediment were transported during a 100—year frequency flood in April 1976——220,000 cubic yards of which came from the remnant deposits. In 1977—78 17,000 cubic yards of highly contaminated sediment from area 3A was removed to the New Moreau secure containment site, along with 170,000 cubic yards of material dredged from the channel just below the old dam site (Malcolm Pirnie, Inc., 1980). 4—1 ------- • LIMIT OF 100 YEAR FLOOD STAGE FIGURE 4 -I PLAN VIEW, REMNANT DEPOSITS HUDSON RIVER PCB SITE, HUDSON RIVER, NY SCALE: I” 2,000’ NUB ____CORPORIC T(JNJ 0 A Halliburton Company REMNANT AREA AREA IA REMNANT AREA 2 AREA 2 SARATOGA COUNTY REMNANT AREA $ 4 COVERED BY THE $00 YEAR FLOOD ------- Remnant deposits contain high amounts of sawdust, wood chips, and other debris remaining from a once thriving lumber industry. Because of their high organic carbon content and their proximity to the former G. E. discharge points, the remaining exposed deposits are among the most highly contaminated sediments in the river. Results ol core sampling b the NYSDEC and Malcolm Pirnie, Inc., are summarized In Table 4—1. The values in the table represent the latest volume and mass estimates by NYSDEC (Tofflemire, 1980a). Arithmetic average PCB concentrations on a dry—weight basis ranged from 5 to 1000 ppm. Estimates of the PCB mass In the remnant deposits ranged from 64,000 pounds to 140,000 pounds (Malcolm Pirnie, Inc., 1980). The most highly contaminated sediments were generally found in the top few inches- of the 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 bank to a maximum near the old pool shore. This trend is characteristic of the river below the remnant deposits and is related to velocity distributions and sediment characteristics as will be discussed later. The remnant deposits were subjected to a number of remedial activities between 1974 and 1978, the most significant of which was the excavation and containment of 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, has not been subjected to - any remedial action. The aerial inspection in 1983 showed It to be much smaller than before. Figures 4—2a through 4—2e depict typical cross sections at the remnant deposits and relate contaminated material and remedial construction features to river stages. 4-3 ------- TABLE 4-’! PCB CONTAMINA11ON IN REMNANT DEPOSITS Avg. PCB Contaminated Contaminated PCB Remnant Area Concentration Depth Volume Mass Area ( acres) ( ppm) ( ft) ( yd 3 ) ( Ib ) 1 4.0 20 2 12,900 450 2 8.0 5 5 64,530 570 3 13.3 65 8 160,925 18,550 3a 6.0 1000 1 9,680* 17,000* 4 12.0 25 2 38,720 1,700 4a 8.5 40 3 41,140 2,900 5 4.0 250 8 31,630 22,650 Total 55.8 359,525 63,820 Less Area 3a 17,000 Remaining 46,820 Source: (Tofflemlre, 1980). * The actual volume excavated from area 3a in 1978 was 14,000 yd 3 . Based on an assumed bulk density of 65 lb’ft ” 3 the PCB mass removed from Area 3a could be 24,500 lb. The remaining mass of PCB, however, does not change. 4—4 ------- WEST EAST 150 L ii I ii tL -J hi > hi I4O 4 - hi 100 YEAR FLOOD U) ______ GROUND hi ___ AVG. ANNUAL FLOOD ___________________________________ 0 m (11 . I3O 90% DURAT ___________________ z 0 Lii 120 I hi 0 200 400 DISTANCE (FEET) SOURCE’ TRANSECT 92+00, MALCOLM PIRNIE (1977) FIGURE 4-2a TYPICAL CROSS SECTION AT REMNANT DEPOSIT 1 FIII I%JLJB _ ORPORA11ON HUDSON RIVER PCB SITE, HUDSON RIVER, NY 0 A Halliburlon Company ------- WEST EAST 0 200 400 MARCH 1976 SOURCE. TRANSECT 80400, MALCOLM PIRNIE( 1977) DISTANCE (FEET) FIGURE 4-2b TYPICAL CROSS SECTION AT REMNANT DEPOSIT 2 NUB _CORPORA ON 0 A Haltiburton Company 150 140 p w Iii IL -J tiJ > w -J 4 Iii U) I d m 4 z GROUND SURFACE 130 - DEPTH .nn EXISTING BANK HUDSON RIVER PCB SITE, HUDSON RIVER, NY ------- ‘Ii U- -J U > U i -J U (I) U > 0 0 2 0 I- LU -J LU WEST 145 135 125 115 — SOURCE: TRANSECT 52440, MALCOLM PIRNIE (1977) 0 400 DISTANCE (FEET) TYPICAL CROSS SECTION AT REMNANT DEPOSIT 3 NUS _CORPOR flON 0 A Halhburton Company ASSUMED TOP OF STONE RIP-RAP EAST GROUND SURFACE AVG. CONTAMINATED DEPTH I 200 HUDSON RIVER PCB SITE, HUDSON RIVER, NY FIGURE 4-2c ------- WEST EAST LU 145 L ii LL GROUND SURFACE -J Lii > Lii ASSUMED TOP OF STONE 135 RIP-RAP 100 YEAR FLOOD AVG. CONTAMINATED AVG. ANNUAL OOD m 125- 9Q0 DURATION FLOW 0 I- > I i i II ‘ - I bi 0 200 400 DISTANCE (FEET) SOuRCE TRANSECT 20600, MALCOLM PIRNI E (1977) FIGURE 4-2d TYPICAL CROSS SECTION AT REMNANT DEPOSIT 4 HUDSON RIVER PCB SITE, HUDSON RIVER, NY I Icon oFv rIoN A Halliburton Company ------- WEST 145 DISTANCE (FEET) SOURCE TRANSECT 2400, MALCOLM PIRNIE (1977) TYPICAL CROSS SECTION AT REMNANT DEPOSIT 5 FIGURE 4-2e jNUB ____CORPORATPN 0 A Halliburton Company GROUND SURFACE EAST 135 ASSUMED TOP OF STONE RIP-RAP 125 - I 0 200 DEPTH 400 HUDSON RIVER PCB SITE, HUDSON RIVER, NY ------- Ninety percent of the time the pool 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 PCB 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 (see section 4.1.2.2 for a discussion of groundwater migration potentials). 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 dèsorbed PCBs would be carried inland where it would be attenuated by soil particles. Although air transport from the remnant deposits is surprisingly high, WAPORA, Inc., (1980) concluded that PCB redistribution in rainfall and dry deposition Is not a significant -component to the total PCB mass balance. 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. Tof-flemire and Quinn (1979b) suggested that after remedlation, the unstable bank areas of remnant deposit 4 presented the greatest potential for future erosion losses. The most highly contaminated deposits, areas 3 and 5. are not likely to erode because they are adequately protected against flows substantially higher than the average annual flood. Consequently, it Is contended by some NYSDEC officials that the majority of the PCB contamination which moves into lower reaches comes from contaminated bottom sediments and not from remnant deposit scour, because the remaining unstable remnant areas are not highly contaminated. 4.1.1.2 Upper Hudson River Sediments The NYSDEC and its consultants began an extensive survey in 1976 to determine the magnitude of PCB contamination In Upper Hudson River sediments. Over 1200 core and grab samples were taken from a 40 mile stretch of river from 1976 to 1981. Approximately 700 of these were analyzed for PCBs and a large number of 4—10 ------- samples were tested for particle size class distribution, volatile solid content, heavy metals, and the radioisotope cesium 137 O 37 Cs). The bulk of sediment sampling was completed in 1977. The main survey consisted of 640 grab samples collected along surveyed transects which were more common near Fort Edward and less closely spaced down river, plus an additional 200 core samples which were recovered randomly from soft near—shore deposits. A second survey in 1978 included 200 grab samples collected to refine the results of the 1977 sampling effort. No major sediment surveys (>50 samples with accompanying PCB analysis) have occurred since 1978. The major findings of numerous studies are discussed below. Estimates of mean PCB concentrations and mass vary from report to report depending on the type of averaging used, how sectioned core samples were averaged, and the method used to determine depth and areal extent of contaminated deposits. Table 4—2 gives a summary of typical statistics collected from various sources characterizing deposits. The mean PCB concentrations in the table reflect frequently reported arithmetic means; yet it should be considered that the frequency distribution of PCB levels Is log normal and these values may not be the best estimates of central tendency (Toftiemire and Quinn, April 1979). The distribution of PCBs on the river bottom is extremely variable. Tofflemire and Quinn (April 1979) reported an overall standard deviation of 188.2 ppm for 434 grab samples with a mean of 66.7 ppm. Malcolm Pirnie, Inc., (1978) noted that very high PCB levels could be fo.und close to e ctremeiy low values; for a single sampling curve they reported PCB levels ranging from 0.02 ppm at 28 inches in one core sample, to 2273 ppm at a 4—inch depth in a core that was recovered less than 1300 feet from the first. The highest single PCB concentration ever found was 3707 ppm, while values below detection limits have occasionally been observed in the contaminated zone. The concentration of PCB decreases with distance below the former disharge points. The decreasing PCB gradient, however, is not regular. Average PCB concentration decreases from 86.2 ppm in the Thompson Island Dam pool to 14.2 4-11 ------- TABLE 4-2 STATISTICAL CHARACTERISTICS OF PCI) AND PCB MASS ESTIMATES FOR RIVER REACHES IN ThE UPPER HUDSON RIVER Arithmet lc(b) Mean PCB (ppm) MPI(d) NVsDEc(°r Reach(a) Total(b) %(C) Sample(C) No. Samples Dens lt Samples >50 ppm per ml Standard” Deviation (ppm) PCB Mass (Ib ) 9 6 —- —— 297.2 -— 900 3.000 8 301 25.1 430 86.2 245.3 133.700 117.600 7 86 30.0 253 64.0 63.3 18.900 15.600 6 126 37.0 300 76.0 141.2 41.600 48.900 5 98 12.2 50 14.2 17.2 62.100 42,600 4 35 22.0 69 39.7 74.9 23.700 15.200 3 18 14.3 35 42.7 105.7 24.800 18.000 t 2 18 12.5 27 13.4 17.8 16.900 13.500 R 1 18 14.0 20 9.6 12.0 23.800 12,500 Total 706 66.7* 188.2* 347,200 286.900 NOTE: Footnotes appear on Page 2 of this table. ------- TABLE 4-2 STATISTICAL CHARACTERISTICS OF PCB AND MASS ESTIMATES FOR RIVER REACHES IN ThE UPPER HUDSON RIVER PAGE TWO a. Average Length WIdth Reach Location ( In) ( ft) Area 1 Troy Dam to Lock 1 5.5 845 560 2 Lock 1 to Lock 2 4.0 875 420 3 Lock 2 to Lock 3 2.6 1.050 330 4 lock 3 to Lock 4 2.2 1.230 330 5 Lock 4 to Lock 5 15.2 690 1,260 6 Lock 5 to Lock 6 1.8 800 270 7 Lock 6 to Thompson IS (670) c Dam 2.3 790 220 8 Thompson Is. Dam to 5.2 710 445 Rogers Island 9 Rogers Island to Bakers Falls b. Source (Tofflemire and Quinn. April 1979). c. Sources (Malcolm Pirnle Inc.. January 1978). d. Source (Malcolm Pirnie Inc., September 1980). e. Source (Tofflemlre. March 1980). * StatistIcs for grab samples only. ------- ppm In the Lock 4 pool and then increases again in the Lock 3 and Lock 2 pools to 39.7 and 47.7 ppm, respectively. The smaller value for the Lock 4 pool may be related to the poor sampling density relative to adjacent sections. However, Tofflemire and Quinn (1979) proposed that the rate of deposition of PCB— contaminated sediments in the downstream reaches is high compared to the Lock 4 reach because of the wider channel and the presence of many low—velocity marsh areas where PCB—Iaden sediments tend to accumulate. They also suggest that unidentified additional PCB sources on the west side of the river near Mechanlcsville may be responsible for the rise in PCB concentrations in the Lock 2 and 3 pool sediments. Total PCB mass estimates also tended to decrease with distance downstream. Mass estimates for the Upper Hudson River varied betwen 290,000 pounds and 350,000 pounds (Malcolm Pirnie, inc., 1980). The rahge in mass estimates for river reaches is illustrated in Figure 4—3. The lateral distribution of PCB—contaminated sediments is influenced by a number of. factors. Typically. PCB levels In channel sediments and along eroding banks are lower than those in soft, near—shore deposits (Malcolm Plrnie, Inc., 1980). This trend is related to sediment particle size and composition and the variation of flow velocities across the channel. Tofflemlre and Quinn (1979) statistically determined that high PCB values are associated with finer sediments which are rich in organic carbon. These associations are attributed to the high surface area to volume ratio of the inorganic fraction and to the high affinity of PCBs for carbon. Organic mucks normally collect in low—velocIty areas in marshes and backwaters and to a lesser extent near the shore. The NYSDEC has shown that mean log 10 PCB levels of the Outer two thirds of the river area are statistically higher than those of the middle third (Toffiemire & Quinn, 1979). Typically the PCB concentration of near— shore deposits ranged from 50 to 1000 ppm, while concentrations In the coarser sediments from the channel ranged between 5 and 20 ppm. The variation of PCBs with depth in the sediment profile differs with the reach of the river considered. In the Thompson Island Dam pool, peak mean PCB levels of 4—14 ------- SOURCE :(MALCOLM PIRNIE INC. 1980). FIGURE 4-3 ESTIMATED PCB IN POUNDS BY RIVER POOL NUS _coR JR O J 0 A Halliburlon Company a) 0 I L C ,) 0 z 0 0 0 L i i 1- U) Lii -a U i REMNANT THOMPSON DEPOSITS ISLAND DAM RIVER LOCATION LOCK LOCK LOCK 3 2 FEDERAL ESTUARY DAM HUDSON RIVER PCB SITE, HUDSON RIVER,NY ------- 133 ppm were found between 12 to 18 inches in depth. As distance below the Thompson Island Dam Increased, peak mean PCB levels decreased, peak levels were found closer to the surface, and the distribution of PCBs within the profile became more homogeneous (Tofflemire and Quinn, 1979). Malcolm Pirnie, Inc., (1978) proposed a dredge depth of 24 inches for the Thompson Island Pool to avoid exposing highly contaminated sediments to the water. A 15—inch cut was proposed for all other areas. To view the areal distribution of PCB contamination In the river, offIemire and Quinn (1979) plotted all survey data on one inch to 200 feet scale planimetric maps and drew isoconcantration contours to delineate PCB Thot spots. Sample points exhibiting a PCB concentration of 50 ppm or more were the primary criteria for drawing contours. Subjective judgments based on knowledge of sediment composition and river hydrology were used to locate boundaries when survey data were scarce. The arithmetric mean PCB concentration of all samples within a hot spot was compared with the mean value of the adjacent cold area, and the hot spot boundaries were adjusted until the average concentration was 50 ppm or more. Using this method, 40 hot spots were identified within a 40—mile section of river stretching from Rogers Island to Mechanicsvllle. The location and configuration of NYSDEC PCB hot spots are shown in Figure 4—4. Tofflemire and Quinn’s detailed tabulation of hot—spot concentration and mass estimates Is reproduced in Table 4—3. From this table It Is evident that, hot spots as delineated by NYSDEC in 1978 contained 58 percent of the estimated PCB mass within the Upper Hudson River while only covering 8 percent of the area. Hot spots are regarded as conservative but adequate estimates of the configurations of areas of major PCB contamination in the river in 1977 to 1978. PCB distributions around hot spot number 6 were further examined using a computer application of a digital extrapolatIon/InterpolatIon technique. The program used gradient analysis and inverse distance methods to approximate PCB concentra.tions for points at 50—foot grid intervals. Isoconcentration contours were 4—16 ------- (Source — Malcolm Pirnie Sept. 1980) Co. GLENS FALLS - HUDSON FALLS FIGURE 4-4 HOT SPOT AND REMNANT AREA LOCATIONS HUDSON RIVER PCB SITE, HUDSON RIVER, NY NOT TO SCALE I NUS ____CDRPORATKJ1 J 0 A Halliburlon Company ALBANY CO. AIRANY RENSSELAER WAI -I Tiop Lock SARATOGA CO. MECHANIC VILLE ock 3 RE NSSELAER Lock I C WARREN Lock 4 I Fo’t FIG.4-41 Own Site I-. FIG. 4-4s I I— FIG. 4-4d I hompion Is Oem FIG. 4-4c ID WARD WASHINGTON Co. ------- LEGEND : REMNANT AREA PCB HOT SPOT STREAM MILE ABOVE THE BATTERY PLAN VIEW UPPER HUDSON SCALE: ¼: I MILE FIGURE 4- 4a NUE ___CCP RAT1 N 0 A Hailiburton Company RIVER AREA 4-18 ------- LEGEND : Is PCB HOT SPOT o—t i STREAM MILE ABOVE THE BATTERY THOMPSON FIGURE 4-4b PLAN VIEW UPPER HUDSON SCALE: 1Y4’:I MILE RIVER / RLi\ NUB ____CORPORAT(JN 0 A Halliburton Company . LOCK -a C D FORT MILLER -4 10 I.” 0l ‘0 ia I ------- PCB HOT SPOT —iae STREAM MILE ABOVE THE BATTERY HGURE 4-4c PLAN VIEW UPPER HUDSON RIVER AREA SCALE: I/ 4 N I MILE NUS _COAPOFW1ON 0 A Halliburton Company (0 z ‘0 0 r ‘SI. 2 10 LOCK 5 6) C U I LEGEND : ------- — / ISARATOGA NATI0 I H%S1O L PAR) -J I -. - - -- •_-.-_--_-—Jl LEGENDS I8 PCB HOT SPOT °—iee STREAM MILE ABOVE THE BATTLR UPPER HUDSON RIVER SCALE:. I V 4 I MILE AREA [ NUS ____CORPORATKJN 0 A Halliburton Company F ) 2 fill -1 0 C l C m ‘ L i C D Li 0 I- (I ’ C, LLI z x 0 r LAN VIEW FIGURE 4-4d ------- I L 0 ’ I- z C -l 0 11 C) C ml ( 1 LEGEND : PCB HOT SPOT o—188 STREAM MILE ABOVE THE BATTERY FIGURE 4-4e PLAN VIEW UPPER HUDSON RIVER AREA ‘ SCALE i’4’ I MILE L_ J J CORPORATION 0 A Halliburton Company ------- LEGEND PCB HOT SPOT STREAM MILE BATTERY ABOVE THE FIGURE 4 - 4f PLAN VIEW UPPER HUDSON SCALE: 1V 4 11 = I MILE RIVER AREA [ NUS L COFRPORATKJN 0 A Hafliburton Company 0 tIo I L ’ 0, s L0CK I o—i ae L i i I L 0 I,- 1W Iz -i x 0 ------- LEGEND : PCB HOT SPOT o—1a8 STREN l MILE ABOVE THE BATTERY FIGURE 4.- 4p PLAN VIEW UPPER HUDSON SCALE: IY : I MILE RIVER AREA 4-24 ThEI\!UB ___ OR RAT1ON 0 A Hailiburton Company T OY - 1w M. g -J ------- TABLE 4-3 CONTAMINATED AND REMOVAL VOLUMES AND PCB QUANTITIES OF HOT SPOTS Hot Spot (1) Area No. Area Contaminated (2) Volume Mean (3) PCB Conc. PCB 1 ) Quantity Removal (5) Volume (sq ft) (Cu yd) (ppm) (Ibs) (Cu yd) 1 66,600 3,100 63 340 7,400 2 21,200 1,000 81 140 2,350 3 38,300 1,750 46 140 4,250 4 78,800 3,650 50 320 - 8,750 Subtotal 204,900 9,500 57 940 22,750 5 460,400 34,100 62 3,710 51.150 6 1,033,700 76,550 69- 9,270 114,850 7 110,600 8,200 39 560 12,300 8 1,462,700 108,350 99 18,830 162,500 9 118,500 8,800 38 590 13,150 10 191,200 14,150 78 1,940 21,250 11 57,100 4,250 39 290 6,350 12 45,700 3,400 71 420 5,100 13 28,000 2,050 89 320 3,100 14 974,200 72,150 279 35,330 108,250 15 286,600 21,250 103 3,840 31,850 16 446,500 33,050 380 22,060 49,600 17 83,200 6,150 256 2,770 9,250 18 201,700 14,950 94 2,460 22,400 19 42,000 3,100 83 450 4,650 20 62,700 4,650 249 2,030 6,950 Subtotal 5,604,800 415,150 144 104,870 622,700 21 30,800 1,450 143 360 3,400 22 97,600 4,500 75 600 10,850 23 4 I,000 2,050 506 180 4,900 24 129,000 5,950 506 520 14,350 25 300,100 13,900 100 2,440 33,350 26 119,800 5,550 47 460 1,300 27 78,400 3,650 63 . 340 8,700 Subtotal 799,700 37,050 75 4,900 88,850 4—25 ------- TABLE 4-3 CONTAMINATED AND REMOVAL VOLUMES AND PCB QUANTITIES OF HOT SPOTS PAGE 2 1. Hot Spot Area No. 1—4 5—20 21—27 28—35 36 37 38—40 Above Lock 7 Thompson Is. Dam — Lock 7 Lock 6 — Thompson Is. Dam Lock 5 — Lock 6 Lock 4 — Lock 5 Lock 3 — Lock 4 Lock 2 — Lock 3 9 8 7 6 5 4 3 2. Contaminated Volumes based on a contaminated depth of: 15 in. — Above Lock 7 24 In — TID — Lock 7 15 In. — Lock 6 — TID 15 In. — Lock 5 — Lock 6 15 In. — Lock 4 — Lock 5 15 in. — Lock 3 — Lock 4 15 in. — Lock 2 — Lock 3 Hot Spot (1) Area No. Area (sq ft) 1,026,800 32,700 54,400 194,300 41,200 119,400 955,800 245,400 2,670,000 Contamlnated( 2 ) Volume (Cu yd) Mean( 3 ) PCB Conc. (ppm) 109 81 155 516 51 98: 159 105 155 PCB( 4 ) Quantity (Ibs) 9,090 220 690 8,150 170 950 12,350 2,090 33,710 Remova l( 5 ) Volume (cu yd) 114,100 3,650 6,050 21,600 4,600 13,250 106,200 27,250 296,700 47,550 1,500 2,500 9,000 1,900 5,550 44,250 11,350 123,000 28 29 30 31 32 33 34 35 Subtotal 36 37 38 39 40 Subtotal 1,207,500 1,239,700 318,850 284,000 743,550 1,346,400 55,900 57,400 14,750 13,150 34,400 62,300 51 116 506 161 62 80 5,000 11,860 1,300 3,720 3,750 8,770 134,140 137,750 35,450 31,550 82,600 149,600 Total 13,073,000 760,300 127 169,870 1,452,500 Reach 4—26 ------- TABLE 4-3 CONTAMINATED AND REMOVAL VOLUMES AND PCB QUANTITIES OF HOT SPOTS PAGE 3 3. Mean PCB Conc. based on average concentration of all surface samples and weighted average concentration of core samples within the hot spot area. 4. PCB Quantity based on a bed material density of 65 lb/cu ft. 5. Removal Volume based on a 36 in. removal depth. Source: Toffiemire and Quinn, April 1979. 4-27 ------- then fitted to the grid points. As might be expected, hot spots appeared as localized cells of influence on the river bottom. However, a grouping of these cells corresponds with hot spot number 6 as mapped by NYSDEC. PCB hot spots shown in Figure 4—4 are generally a manifestation of the trends described earlier In this section. Many hot spots encompass areas of fine, organic—rich—matter sediments isolated along quiet banks and in shallow, low velocity marsh areas. Often, however, highly contaminated deposits are found near the center of the channel and on the outside banks of bends where they would not normally be expected to occur. This characteristic is more pronounced closer to the old Fort Edward Dam site and is explained by the tremendous oversupply of sediment occurring after the removal of the dam. Normally a mature river such as the Hudson is in a dynamic equilibrium state with its basin such that the overland sediment supply neither greatly exceeds nor falls substantially below the sediment transport ability of the river (Chow, 1964). if the sediment supply suddenly increases as a result of dam removal, for example, the net effect is a steady sediment buildup over the entire river bed. This appears to be the case with the sediments in the Thompson Island pool, and the PCB profile within the sediment column provides support for this hypothesIs. The fact that peak levels of PCB are relatively well defined and buried beneath 6 to 8 Inches of cleaner sediment mirrors the effects of a mass release of highly contaminated sediments with the removal of the Fort Edward Dam and the deposition of less contaminated sediments corresponding to the virtual elimination of PCB from the G.E. dIscharges (Brown and Werner, 1983). D’ownstream, highly contaminated PCB hot spots are found more often in classic low—velocity marsh areas and backwaters, and the homogeneous distribution of PCB with depth in the profile indicates a more uniform and diffuse dispersal of PCB—Iaden sediments. This is explained by the slow return of the Thompson Island pool to an equilibrium state after the removal of excess sediment supply with the stabilization of the remnant deposits. Consequently the flux of sediment to lower reaches is lower and substantial deposition does not occur except when suspended 4—2B ------- sediments are washed into low—velocity deposition areas. As the river sediments return to equilibrium, scour from the Thompson Island pool can be expected to decrease and the PCB load to the estuary should show a similar trend. The transient nature of sediment deposits, however, cannot be overemphasized. The effects of excessively large flows on deposits in the Thompson Island pool. especially those now occupying high velocity areas, are unknown. Perhaps even the disturbance caused by barge traffic Is enough to destabilize some hot—spot areas. It is possible that the hot—spot mapping done in 1978 may not be valid in 1983, especially with the return of flows exceeding 50,000 cfs at Waterford in May. Refer to AppendIx E for a discussion of the results of recent sedIment sampling In the U per Hudson. 4.1.1.3 Lower Hudson River Sediments Sediment sampling by the Lamont Doherty Geological Observatory has provided valuable information on PCB contamination In the reach below the Federal Dam at Troy. Their surveys routinely include analysis for the 137 Cs Isotope which is useful as an independent indicator of the recent nature of sediments that can be used to date sediments and compute deposition ‘rates (Bopp, 1979). Lamont Doherty data (Table 4—4) show a regular decrease in PCB levels with distance below the Federal Dam (Bopp, 1979). Average concentrations ranged from 3 ppm In the Upper .Harbor area to 30 ppm near Albany. The highest PCB concentration measured by Lamont Doherty was 140 ppm found in a core from the Albany turning basin. The overall average PCB concentration of the Lower Hudson River Is about 10 ppm, which is considerably less than that of the Upper Hudson River, but which is one to two orders of magnitude more contaminated than other water bodies in the area (Bopp, 1979). Using the absence of 137 Cs as a stratigraphic indicator of pre—1954 conditions, Bopp estimated that pre—G.E. discharge PCB levels were 0.2—0.6 ppm, which Is more in line with recent sediments from other rivers. 4-29 ------- TABLE 4-4 CONTAMINATION OF PCBs (Arockr 1242) IN RECENT SEDIMENTS OF THE LOWER HUDSON RIVER No. of Samples ___________________ averaged _________ __________ (1.6 —140) (4.1—29) (0.5—26) (0.7—5.8) All samples with 137 Cs at least two standard deviations greater than zero were included In the average. This value may be somewhat misleading because of extremely high values in the top 60 cm of core 143.4. Eliminating this core gives an average of 16 ppm 1242, with a range from 7.6 to 35 ppm. Source: Bopp, 1979 Cores (mile paints ) 146.3, 144.2, 143.4 109.5, 91.8 , 83,2 53.8, 44.4, 43.2 6.0, 0.1, — 1.5 PCB (1242) Concentration, 21 24 25 27 Range - ppm Average ppm 30 10 6 3 4—30 ------- From basic data on PCB concentrations and sediment deposition rates developed from the Lamont Doherty data, Bopp, et al., (1980) estimated the area! distribution of PCB contamination and developed a rough PCB mass balance for the Lower Hudson River. The preliminary results of this analysis are presented In Table 4—5. Low deposition areas which accumulated little or no recent sediment, such as channel and subtidal banks, made up approximately 65 percent of the river area but contained only about 14 percent of the PCB burden associated with bottom sediments. Coves and broad shallow areas where deposition was on the order of 1 cm/yr accounted for 25 percent of the area and 35 percent of the PCB contamination. The remainder of the PCB—contaminated sediments had been deposited in frequently dredged areas where accumulation rates of 5—20 cm/yr were common. Most of this area was in the New York harbor, but other high deposition areas were identified In the river near Kingston and Germantown and in the Albany turning basin. Bopp estimated that between 1960 and 1980 over 86,000 pounds of PCB were removed from these areas by maintenance dredging. From data on PCB partitioning between sediment and water, Bopp further estimated that 200,000 pounds of PCB have left the river with the water. The EPA obtained two sets of core samples for PCB analysis from 29 stations in the Lower Hudson In 1976 and again in 1981 (U. S. EPA 1977, 1981). For the most part, PCB levels in 1981 were less than half of those measured in 1976. In 1976, the highest total PCB values were 58.3 ppm (dry weight basis), measured in the Albany turning basm. In 1981, the Albany turning basin sample had a depth— weighted average of only 6.9 ppm. The overall average decrease In the top half of the cores was 11.3 ppm and the average decrease in the lower core segments was 10.5 ppm. The only sample showing an Increase in PCB concentration was collected at Foundry Cove, which Is located north of West Point. PCB levels in the top portion of the cores increased from 11.07 ppm to 15.8 ppm, and PCB concentrations in the bottom sections increased from “not detected” to 0.06 ppm. No explanation for the drastic decreases which were observed has been developed. Bopp (1979) has provided evidence which shows that the more highly chlorinated 4-3 1 ------- TABLE 4 ’5 PREUMINARY PCB BALANCE FOR ThE LOWER HUDSON Location 1. New York Harbor ( in—situ ) 2. Coves and Marginal Areas a. Coves and bays b. Havarstraw Bay and Tappan Zee 3. Low Deposition Areas (Channel & Subtidal Bank) 4. Upstream Areas of High Deposition a. Albany Turning Basins, mp 109.5 and Lent s Cove b. Kingston area Total PCBs associated with sediments of the Lower Hudson ( in—situ ) PCBs dredged from New York Harbor washed out to sea TOTAL Source: Bopp et al., 1980 PCB Burden (pounds) 54,000 24.000 36 . 000 24,000 5,000 26,000 169,000 86,000 200,000 455,000 Total PCB5 4-32 ------- PCB isomers are preferentially adsorbed onto particles. Depletion of the more volatile Aroclors (1016 and 1242) in sediments may partly explain the decreases in PCB concentrations which occurred between 1976 and 1981. It Is also possible that sediments had been disturbed and reworked or that contaminated sediments observed in 1976 had been buried under cleaner sediments. Although the variability of PCB levels in the sediment is high, it is unlikely that the differences in the results of the two EPA surveys were due to minor errors in relocating the sample stations since 28 of the 29 stations showed drastic decreases. The results of the 1976 EPA survey suggested the existence of five PCB hot spots in the Lower River. These Included, from north to south, the Albany turning basin, the Germantown reach, Foundry Cove, Peeksklll Bay, and Pierport Marsh. Table 4—6 compares the results of the 1976 EPA survey with the results of two other surveys in these areas. The values in the table do not agree well. Bopp, et al., (1980) maintain that PCB values obtained from these areas fall wIthin the variability of the general patterns of contamination observed through the river and that the Idea of anomalous hot spots is erroneous. 4.1.2 Water 4.1.2.1 Surface Water PCBs entrapped in stream bed deposIts are an environmental concern because of the potential for their- uptake and biomagnlfication in the aquatic food chain. However, when these PCBs enter the water column via sediment scour, bloperturbation, or other physical or chemical processes, not only do they become available for direct uptake by a larger segment of the aquatic communIty, but they can now migrate by way of flowing water to previously uncontaminated areas or even to critical receptors such as potable water supply Intakes. Further, the PCBs can enter the atmosphere, creating the potential for bioaccumulatlon In the terrestrial food chain and directly threatening air breathing organisms. It Is for these reasons that PCB health criteria and related monitoring focus on the water column concentration of PCB rather than on the sediment PCB content. 4-33 ------- TABLE 4-6 COMPARISON OF SURVEY DATA FROM SUSPECTED HOT SPOTS IN ThE LOWER HUDSON RIVER EPA 1976 Bopp EPA 1981 Survey 1979í Survey Location ( ppm) ppm ppm - Albany 58.3 140 9.81 River miles 143—146 Germantown 2.5 5 ND River miles 108—109 Foundry Cove 11.7 26 15.8 River miles 53—54 Peekskill Bay 11.7 8 0.92 River miles 44—45 Pierpont Marsh 56.4 4 0.33 River miles 22—24 - ND — Not Detected (<0.01 .ig/g). Compilation by NUS Corporation. Pittsburgh, Pennsylvania. August 1983. 4-34 ------- Since March 1977, the USGS has regularly collected PCB concentration and suspended sediment data from the Upper Hudson River at the Glens Falls, Rogers Island, Schuylerville, Stillwater, and Waterford gaging stations. The agency has also obtained limited records of PCB concentration data from the Lower Hudson River at stations near Castleton, Catskill, Staalsburg, Clinton Point, and Highland. This section presents and discusses the major conclusions of a number of previous studies that examined these data. Filtration of raw river water samples and subsequent analysis of the two fractions (Table 4—7) has shown that the water column contains PCBs in both dissolved and adsorbed forms (Bopp, 1979; ,Turk and Troutman, 1981; Tofflemire, 1980). The adsorbed form is associated with sediment particles in transport. The amounts of dissolved PCBs are often surprisingly high (up to 0.50 ppb) considering the relatively insoluble nature of the compound. The predominant form in the water column at any given time is highly dependent on the flow rate. This relationship Is addressed in depth in subsequent paragraphs. Unless otherwise noted the PCB concentrations of river water reported herein are total values reflecting the sum of both forms. The concentration of PCBs in Hudson River water is related to flow rate in a manner that makes identification of trends extremely difficult. A plot of river discharge rate versus PCB concentration for three years of data collected at Stiliwater and Schuylervllle is shown in Figure 4—5. The plot shows that at low flows, PCB concentration decreases with Increasing river discharge and that above a critical flow range, PCB concentration increases in direct proportion to discharge (Turk and Troutman, ‘1981). Similar relationships exist at all gaging stations on the Upper Hudson River. This bi—modal relationship is thought to correspond to two different processes affecting the transfer of PCB from contaminated—bed deposits to the water column. At low flows desorbed PCBs are Introduced by physical—chemical processes which are not yet fully understood. This transfer occurs at an approximately constant rate and, therefore, as discharge increases, dilution takes place and the PCB concentration drops. The rate at which PCB is supplied to the 4—35 ------- TABLE 4- 7 PHYSICAL PHASE OF PCBs IN WATER COLUMN (WATERFORD) Discharge Concentration (p /l) Date ( ft. 3 sec -1) Dissolved Total 77 Mar 11 15,900 0.0 0.0 13 24.400 0.0 0.0 14 65,500 0.0 0.9 15 70.500 0.0 1.4 17 38,500 0.0 0.0 23 16.400 0.2 0.2 78 Jul 5 580 0.5 0.6 10 1,120 0.4 0.3 17 1,160 0.3 0.4 79 Mar 6 30,400 0.0 0.8 7 47,400 0.2 0.3 79 Jul 5 2,540 0.2 0.3 16 1,810 0.4 0.4 23 1,860 0.3 0.3 79 Aug 06 2,500 0.2 0.4 9 2,800 0.0 0.5 13 1,600 0.1 0.2 79 Nov 27 21,800 0.0 0.3 28 27,200 0.0 0.4 80 June 23 1,550 0.1 0.2 July 4 1,100 0.2 0.4 28 1,882 0.1 0.3 Source: Tofflemire, 1980 4—36 ------- I0 0 0 0 . w U i > RELATIONSHIP BETWEEN FLOW RATE A TOTAL PCB CONCENTRATION FOR SCHUYLERVILLE AND ST1LLWATER DATA HUDSON RIVER PCB SITE, HUDSON RIVER, NY FLOW (CFS ) FIGURE 4 5 . - fl NUB _CC AT N 0 A Hailiburton Company WATER YEAS 5 — £ 1976 1977 • 1977 l978 ______ €) 1978 1979J NOTE: AU.. .0 VALUES PLOTTED AS .03 PPB £ £ £ I 1 • • • . ‘p £ • • . £ / p .5 .1 .05 .03 £ / £ / I / ‘I 1,000 5,000 10,000 50,000 100,000 4-37 ------- water column at low flow was estimated by the USGS to be about 6.6 pounds per day (Turk and Troutman, 1981). As discharge continues to increase, a flow velocity is reached wherein -the tractive forces at the sediment—water interface begin to exceed the forces holding sediment particles in place. At this point, sediments are resuspended into the water column. Since the amount of reentrained PCB—contaminated sediment has been observed to be proportional to river discharge, the total PCB concentration likewise increases with flow rate. Plume experiments on Hudson River sediments have shown that the critical velocity at which resuspension occurs for cohesive sediment is about 1.8 ft/sec. Resuspension of coarser, particles was observed to take place at a lower flow velocity of 1.2 ft/sec (Zimmie, 1981). These flow velocities roughly correspond to the average annual flood stage. The significance of these relationships is that at low flows, PCBs are present predominantly in a dissolved state, and at high flows PCBs are mostly associated with the suspended sediment load. The transition from one form of PCB to the other is not fixed at a certain discharge, and at intermediate flows, PCBs are thought to be present in both desorbed and adsorbed forms. Hand—fitted relationships such as those shown in Figure 4—5 reveal that the transition from one form of PCB to the other varies at flows ranging from 10,000 c-ft to 20,000 cfs. However it is quite evident from Table 4—7 that significant sediment—borne PCBs can be present at flows as low as 1000 cfs. Commonly, PCB concentrations at the Glens Falls station, which is located above this former discharge point, are less than USGS detection limits (0.1 ppb). At the downstream stations the USGS has reported PCB concentration ranging from• detection limits to over 5 ppb. A significant part of this variability was due to the flow relationships discussed above: however, a large portion remains unexplained. When trying to assess public health concerns some of the data variation can be removed by separating the data into low, medium, and high flow regimes. Toffiemire (1980) has attempted this approach by computing means of several 4—38 ------- years of accumulated data at Rogers Island, Schulyerville, Stiliwater, and Waterford using the 7,000 cfs and 20,000 cfs flow values to demonstrate the three flow regimes. Tofflemire’s summary (Table 4—8) shows that, St low flows, PCB concentrations averaged about 0.6 ppb. Medium—flow PCB concentrations dropped to about 0.2 ppb, and high—flow PCB concentrations rose to an average level of about 1.0 ppb. Because of the variability of PCB transport during high—flow periods, the indentification of time—dependent trends Is best limited to consideration of PCB concentrations at low flows. Table 4—9 presents arithmetic mean concentrations for water samples collected at discharge rates less than 12,000 cfs for the period 1976 to 1981. In this table, reproduced from Tofflemire (1983a), data for Stiliwater and Schuylervllie were combined, and Rogers Island data were divided between east and west channels. Low—flow concentrations at all stations have decreased since 1979, the decrease being statistically significant between 1979 and 1980. The decline ranged from 0.036 ppb in the west channel at Rogers Island to 0.537 ppb at the Stillwater and Schuylerville stations. Overall, the mean low—flow PCB concentration fell from 0.69 ppb in 1977 to 0.11 ppb in 1982 (Brown and Werner, 1983). Even though comparisons between arithmetic averages within a selected range of flow can identify long—term trends and significant differences in the data, the results can also be misieading since the technique involves arithmetic averaging of data that range between one and two orders of magnitude (Figure 4—5). Further, the data at the various gages are not directly comparable due to varying frequency—flow relationships resulting from ‘increased drainage areas and because the data were not collected concurrently at the respective gages. For example, the data for 1977—1979 appear to Indicate that the mean low—flow rate at Waterford is less than the corresponding value at Schuylerville, which has only 55 percent as much drainage area. What is not obvious, is that the 7,000 cfs upper cutoff value is exceeded only about 20 percent of the ‘time at Schuyiervllle, but about 40 percent of the time at Waterford. Consequently, the reported PCB concentrations do not have a common frequency basis. 4—39 ------- TABLE 4-8 AVERAGE PCB CONCENTRATIONS FOR THREE FLOW REGIMES FOR 1977-1979 USGS DATA Low Flow Medium Flow HIgh Flow < 7000 cfs 7000—20,000 cfs > 20,000• cfs Schuylerville Mean Flow 3306 12881 30064 (cf s) Mean PCB 0.665 0.214 1.17 (pg/I) Stillwater Mean Flow 3553 12583 27933 (cfs) Mean PCB 0.594 0.206 1.08 (i. g/l) Waterford Mean Flow 3153 17119 41733 (Cf s) Mean PCB 0.384 0.230 .693 (j . gIl) Less Than — More Than Source: Tofflemire, 1980. 4—40 ------- TABLE 4-9 LOW FLOW PCB CONCENTRATIONS Parameter 3yrs lyr lyr lyr 1976—79 1979—80 1980—81 1981—82 Low Flow Low Flow Low Flow Low Flow *Rogers Island, E.C. Observations 35 17 21 mean PCB ug/g 0.229 0.200 0.067# mean flow cfs —— —— Rogers Island, W.C. Observations 61 18 22 mean PCB ugh 0.131 0.166 O.036# mean flow cfs 3056 2398 2877 Stiliwater — Schuylerville Observations 38+27 26 69 36 mean PCB/ug/l 0.594, 0.665 0.307 O.156# 0.092# mean flow cfs 3550, 3306 2404 3282 3718 Waterford Observations 43 31 20 16 mean PCB ugh 0.384 0.239 0.145# 0.111 mean flow cfs 3153 2298 3400 4615 Source: Toffiemire, 1980. * For Rogers Island, the a year data base, is 1977—80; there is little data for the 1976—77 year. # The 1980—81 means are significantly lower than the 1979—80 means at the .05 probability level. 4—41 ------- The latter shortcoming can be approximately accounted for by adjusting all data for the respective drainage areas under the assumption that average flows are roughly proportional to drainage area. This does not eliminate the extreme variability of the data, however, and any conclusions based on an averaging procedure must be very general and welt scrutinized. An approach more consistent with the scatter of the data is to simply overlay the data from the various sources and to observe general trends and differences. This nonquantitative approach, which eliminates the potential for generating misleading numbers, proved worthwhile in the assessment of previous modeling studies (SectIon 4.3). A conclusion of that effort Is that all the PCB concentration and load data from Schuylerville, Stillwater, and Waterford are indistinguishable within the scatter of the data when corrected for the respective drainage areas -(refer to Figures 4—16 through 4—18). This would not be an obvious conclusion from the quantitative averaging reported In Tables 4—8 and 4—9. PCB transport rates have shown declines corresponding to the decreases in PCB concentrations which have been observed. Figure 4—6 Illustrates some estimates of average annual PCB transport rates based on USGS data from Waterford and Stlllwater. Also shown In this figure Is the 20—year average PCB transport rate predicted by the PCB transport model of Lawler, Matusky, and Skelly (1978). Although the estimates in the figure show a substantially elevated transport rate for 1979, the general trend appears to be declining, with the most recent estimates apparently leveling off to a base loading rate. The trend seems to satisfy a logarithmic relationship with time. The transport rate trends reported above are similar to those predicted by the Law er, Matusky, and Skelly model for the corresponding years. The annual average transport rate from the model (7200 pounds per year), however, is substantially larger than average transport estimates calculated from measured 4-42 ------- 10,000 - C’) -I —a I— 0 a- U) z 4 I— 0 0 0 -J 4 z z 4 1978 1979 CALENDAR YEAR FIGURE 4-6 YEARLY PCB TRANSPORT ESTIMATES HUDSON RIVER PCB SITE, HUDSON RIVER, NY F- NUS _CORPORA ON 0 A Halliburton Company 9022 8,000- 6,000 4,000- LEGEND — TOFFLEMIRE( 1980) — — — BROWN 8 WERNER( 1983) •• s TURK& TROUTMAN(198 1) LMS (1979) 7200 LBS/YR — 6726 6576 6244 I r—-’ I I I I — 1 I 4259 3740 L ... 2 8 .i.....J .o Qee I I I TOFFLEMIRE(I98 1) 4789 LBS/YR R0WN&WERNER(I983)3873 LBS/YR 1 I 2 00 - - L - - - 0 1976 1977 1980 1981 1982 ------- values because of the high transport rates generated by the model In wet years. It Is now suspected that model results are biased because it grossly overestimates PCB transport at high flows and underestimates transport at low flows (see Section 4.3). The possible effect of large river flows, however, Is a concern which Is discussed further in later paragraphs. The elimination of industrial discharges, stabilization of the remnant deposits, and reduction in PCB releases from bed sediments are cited as the primary factors contributing to the overall decline in PCB concentrations observed in recent years (Brown and Werner, 1983). The flow regime and the processes controlling the transfer of PCBs from sediment to water will likely control PCB concentrations in the future. An assessment of the factors controlling the transfer process in relation to recent trends was made by Brown and Werner (1983). The authors found that mixing and covering contaminated deposits with cleaner sediment may have played a part In the declines in PCB concentrations which were observed. The writers further suggested that depletion of more readily volatilized PCB isomers may In part be responsible for the recent trends. It may be that decreases in PCB concentratIons In the water column are directly related to decreases In the PCB content of the bed sediments. Recent sampling from the Upper Hudson River (see Appendix E) Indicates a large decrease in the overall average PCB concentration of the sediments. This trend Is as yet unconfirmed and possible mechanisms that might be responsible, including the degradation of PCB compounds due to environmental exposure, need to be Investigated. It remains to be seen how the flow regime influences trends in PCB contamination. It has been suggested that an absence of excessively high flows W recent years has resulted In the observation of misleading relationships (Sloan and Armstrong, 1980). Inherent In this suggestIon Is the Idea that large floods will rework the sediments, disturb hot spots, and generally expose more highly contaminated sediments to the water Interface, ultimately resulting in an overall Increase in PCB concentration. Table 4—10 summarizes recent flow data from the gaging station at Stiliwater. The maximum daily flow values at StlIlwater have exceeded the 99 percent flow frequency value of 30,000 cfs In all of the calendar years shown except 1978 and 4-44 ------- TABLE 4-10 RECENT FLOW DATA FROM THE GAGING STATION AT STILLWATER Calendar Year 1977 1978 1979 1980 1981 1982 Annual Mean cf S 8,755 6,250 7.732 4,837 5, 614 6.497 Maximum Mean Daily Flow cf S 40,390 17,302 36,581 26.094 31,214 33,721 Mean Annual Discharge 99 percent flood frequency = 5,000 cfs = 30,000 cfs Source: Brown and Werner 1983 4—45 ------- 1980. With the exception of 1980, mean annual flows have been slightly above normal, indicating that the recent annual flow regimes have not been unusually low. The appearance of flow rates greater than 50,000 cfs at Waterford during May 1983 raised concern over the scouring of contaminated sediments. Flows in this range had not been observed at Waterford since March 1977, when peak flows of more than 70,000 cfs were recorded, and It was suggested that perhaps distribution of PCB contaminated sediments had been altered. Preliminary analysis of USGS data for the 1983 flood indicated that PCB transport rates during peak flows were from 175 to 250 pounds per day, which is three times more than usually picked up during annual high flows. Additionally, the ratio of suspended sediment to total PCB concentration indicated that the sediments in transport were three times more contaminated than in previous years, possibly Indicating that some of the more contaminated sediments were being picked up. A plot of instantaneous PCB loads measured at Waterford during spring flood peaks (Figure 4—7), however, reveals that PCB transport in 19ä3 was in line with recent floods and substantially less than PCB transport in 1977. It is Interesting to note that measured PCB loads in 1979 were substantially higher for given flows than In other years. This may be residual effects of disturbances to the bottom occurring during dredging and the removal of remnant area 3a in 1978. At present a definitive statement on the effects of large river flows on water column concentration, PCB transport, and sediment distributions is not possible. Additional monitoring data will be needed before such trends can be identified. 4.1.2.2 Groundwater In 1980, there were approximately 630,000 to 900,000 pounds of PCBs stored in dredge spoil sites and upland municipal landfills in the Upper Hudson basin area (Malcolm Pirnie, Inc., 1980). Study and cleanup of many of these areas is not directly within the scope of this project. Some of these sites (Caputo Landfill, Old Moreau dredge spoil site) are Superfund projects and others (the remaining landfill sites) are being cleaned up as part of the agreement between G. E. and the NYSDEC. However, because they are situated on the banks of the river, the 4—46 ------- I0 LEG END • 1983 o 1982 o 1981 A 1979 6 977 0 I I 10,000 20,000 ,O00 4O 00 50,000 60,000 70,000 FLOW R 1t (CFS) FIGURE 4-7 RELATION OF PCB LOAD TO FLOW RATE DURING SPRING FLOOD FLOWS AT WATERFORD NUB _D CRA11ON 0 A Haibburton Company A 6 A A 0 0• a C ,, C, 4 0 -J C-) 0 . 0 0 • A 0• .0 — 0.I 0.0I 0 6 • HUDSON RIVER PCB SITE, HUDSON RIVER, NY 4-47 ------- dredged disposal sites have a direct bearing on this study because of their PCB contributions to river water as well as their relation to the suitability of the proposed containment site. Weston Environmental Consultants (1978) computed the PCB groundwater migration potential for 12 sites designated by NYSDEC as having significant amounts of PCBs contained In them. The PCB migration potential is the calculated quantity of PCBs leaving a site via groundwater after accounting for PCB adsorption onto soil particles. The calculations were based on preliminary field and laboratory data collected by Weston in 1977. Table 4—11 summarizes the results of the Weston Study. PCB migration potentials were two to three orders of magnitude lower than annual PCB—contaminated groundwater discharge rates estimated with mass balance techniques which did not include the effects of soil attenuation. As a result of the PCB—porous media interactions, the PCB contamination plume was found to advance at velocities approximately two orders of magnitude slower than calculated groundwater flow velocities. The Lock 1 and Lock 2 sites, Buoy sites 212 and 518, the Moreau sites, and special dredge area 13 are dredge spoil areas located on the banks of the Upper Hudson River. Assuming that alt unattenuated PCBs that leave these sites in groundwater discharge enters the Hudson River, then, according to the values in Table 4—11, the total contribution of dredge spoil sites to the Hudson River PCB load is only 17.0 pounds per year. This is a relatively insignificant part of the annual PCB load at Rogers Island. In comparison, PCB losses from these sites as a result of erosion outweigh the losses from groundwater transport Weston estimates based on the Wischmeier equation (Bayer, et al. , 1979) and soil PCB content are summarized for dredge disposal areas in Table 4—12. The total PCB load from this mechanism of 20 pounds per year js still small in comparison with the total PCB balance of the system. 4-48 ------- TABlE 4—li CALCULATED PCB MIGRATION POTENTIAL FROM CONTAMINATED LANDFILLS AND DREDGE SPOIL AREAS IN THE UPPER HUDSON RIVER AREA Groundwater Site Flow Site a Type* MOD PCB Cpncentration ppb PCB Front Advance Velocity ft/yr PCB Migration Potential lbs/yr * A — Dredged material disposal site B — landfill site Lock Number 1 A 1.5 x i0 37.4 1.3 3 x i0 Lock Number4 A 2.0 x iO1 37.4 11.7 4 x Caputo Site 578 B A 2.7 x i0 4.3 x i0 41.7 37.4 2.3 9.9 6 x 8.8 x i0 Site 212 A 2.2 ii 101 16.7 2.1 2.0 x t Old Fort Edward Fort Miller B B 2.0 x 10-1 1.5 x 10—6 693.0 45.1 23.4 1.3 x 10 7.5 c 10-1 3.5 x Klngsburg Moreau B A 1.3 7.4 x io2 580.1 55.4 24.3 2.3 3.8 2.2 x S.A. 13 A 2.9 x 10—1 58.0 2.3 9 , i02 Source: Weston Environmental Consultants 1978. ------- TABLE 4-12 Lock 1 Lock 4 518 Buoy 212 Moreau SA 13 PCB LOSSES TO THE RECEIVING STREAMS UNSECURE DREDGE DISPOSAL SITES 1.66 6.36 16.97 41.05 45.46 27.24 Total PCBs Lost to Watershed lb/yr 0.015 20.8 17.3 24.2 4.2 4.5 Source: Weston Environmental Consultants, 1978. Estimated Soil Loss to Watershed Receiving Stream Tons/YeAr 4—50 ------- The New Moreau site is a secure có ntainment area designed to hold dredge spoils from remnant area 3a and from the terminal channel at Fort Edward. As such, it contains some of the most contaminated sediments in the study area. Details of the site’s construction may be found on Malcolm Pirnie , Inc., contract D95278 drawings. Because the designs and geologic settings are similar, monitoring results from the New Moreau site should reflect the behavior of the proposed Hot—Spot Dredging Program disposal site. PCB analyses are routinely made on samples taken from the leachate collection system and from an upgradlent monitoring well. Unfortunately. there are no downgradient wells and an assessment of leaching cannot be made. Three leachate samples have been collected from the internal drainage system (Treiling, July 1983). since 1978. PCB concentrations in these samples have ranged from less than 0.05 ppb to 1.5 ppb, with an average of 0.46 ppb. The maximum concentration of 1.5 ppb occurred in -September 1979 and again in November 1982. The upgradient monitoring wells have, surprisingly, yielded a higher average PCB concentration of 0.94 ppb for four samples collected between June through November 1982. These concentrations have ranged from less than 0.06 ppb to 3 ppb, which was found in the Weston welt in November 1982. The Weston well is thought to be finished in the unsecure Old Moreau dredge spoil area, which may explain the relatively high PCB value. As of this time, there is not enough groundwater data available to properly assess the performance of the New Moreau containment design. 4.t3 Air Total suspended particulates have been monitored with high—volume air samplers at five locations in the Upper Hudson Valley. Results of the monitoring program are included in Table 4—13. Although most readings were within State and Federal standards, one of the Glens Falls stations exhibited readings that exceeded the standard for the annual geometric mean in 1973 and 1975. Readings obtained in 1976 were again in compliance with the State standard. 4—51 ------- TABLE 4-13 TOTAL SUSPENDED PARTICULATES - hiGh VOLUME AIR SAMPLERS SELECTED STATIONS - UPPER IIIJDSON RIVER 1976 Station NYS Fed. kAas. Sid. G.M. ( p g /rn 3 ) ( pg/rn 3 ) Annual Geometric Mean — pg/rn 3 not to exceed &A.Q.S 1972 1973 1974 1975 1976 24 hour eve. pg/rn 3 no! to exceed A.A.O.S.(3) is! maxi 4 P 2nd max. 3rd max . t C l ’ Glens Fails 75 55(2) 53 56(1) 47 63(1) 45 119 (0) 114 112 Glens Falls 75 65 — — 43 49 43 132(0) 117 93 Fort Edward 75 55 — - — — 36 128(0) 108 91 Mechanlcviiie 75 65 — — — — 45 114(0) 111 107 Troy 75 65 52 55 53 46 39 112(0) 95 92 1. Denotes a violation of Ambient Air Quality Standards. 2. The State is dividod by air quality priorities Into (our levels: Level I. denoting areas of least pollution to Level p.1. areas of heaviest poilullon. The two Giens Fails stations are located in different level areas, thus the difference in the A.A.Q.S. values. 3 Slate standard for 24 hour average Is 250 pg/rn 3 . Federal standard is 260 pg/rn 3 . 4. 1st. 2nd. and 3rd maximum averages measured during 1976. The number in parenthesis Indicates number of times 24 hour max. was exceeded. Source: NYS Air Quality Report Continuous and Manual Air Monitoring Systems NYSDEC 1976 As Printed in: Malcolm Pirnie. Inc.. January 1978 ------- In 1977, PCB air sampling was conducted at five locations in the Upper Hudson Valley over an eight—month period. PCB readings in the Glens Falls and Warrenburg areas were generally less than 20 ng/m 3 , while the stations in the Hudson Falls and Fort Edward areas recorded higher PCB levels. One of the Fort Edward stations, which was in close proximity to the General Electric Company facilities, recorded the highest concentrations, ranging from approximately 60 ng/m 3 to 3260 ng/m 3 (Malcolm Pirnie, Inc., 1978) (see Table 4—14). Thirty—day dustfall jar tests were also conducted for PCBs at stations in the Fort Edward, Glens Falls, and Warrensburg areas in 1977. Results Indicated that PCB contamination of settleable particulates was higher at the Fort Edward area than at either of the other two areas (Malcolm Pirnie, Inc., 1978). About 1979, several field air samples were taken over dump or dredge sites. Sampling was generally conducted 3 to 4 feet above the ground and was repeated about 3 to 5 times. The data Is presented in Table 4—15. - Several background stations in the Fort Edward area had less than 20 ng/m 3 , which is about the detection limit of the method for a 24—hour sample (NYSDEC, 1981). Air samples taken in 1981 wIth a high volume sampler employing polyurethane sponges contained air PCB concentrations of roughly 5 ng/m 3 for farm fields near the Hudson River. Additional air sam ling over the Lock 5 dam during the summer revealed PCB concentrations of 0.11 to 0.52 ng/m 3 (NYSDEC, 1981). 4.1.4 Biota 4.1.4.1 Fish The PCB problem in the Hudson River was first detected in the late 1960’s during a state—wide investigation of DDT contamination In fish (NYSDEC, 1983). Subsequent studies have provided a relative wealth of data for PCB concentrations in aquatic biota. 4—53 ------- TABLE 4-14 NEW YORK STATE - DEPARTMENT OF HEALTH PCB AIR SAMPLING ng PCB/m 3 Glen Falls Warrensburg Hudson Falls Fort Edward I Fort Edward I! Date 5601—4 5660-02 5726—01 5755—01 5755—02 1/1/77 R R R R <30 1/7/77 R LA 40 R R 1/13/77 R R <190 1020 <60 1/19/77 LA <30 LA 530 <20 1/25/77 R <40 R 1800 R 1/31/77 <20 <20 R 1800 <30 2/6/77 <20 <20 50 STB <20 2/12/77 <20 <20 80 500 20 2/18/77 <20 <20 130 360 40 2/24/77 R <20 <20 870 280 t 3/2/77 <50 <30 <20 <600 80 3/14/77 <20 <20 190 60(1) 560(1) 3/20/77 R <20 <20 <320 <70 3/26/77 <20 <20 <20 Th4 0 240 4/1/77 <20 <20 <20 100 130 4/7/77 <20 NR 100 1210 <20 4/13/77 <20 <20 120 1180 160 4/19/77 <20 <20 160 740 200 4/28/77 <20 <20 260 3060 <20 5/3/77 <20 <20 30 330 210 5/13/77 <20 <20 <20 850 120 5/19/77 <20 <20 <20 580 100 5/25/77 R <20 200 1140 130 5/31/77 <20 <20 100 970 <20 6/6/77 <20 <20 30 R 320 6/12/77 <20 <20 20 130 30 6/18/77 R R R 90 R 6/24/77 R <20 R R 30 6/30/77 <20 <20 110 3260 <20 7/6/77 <20 20 140(2) 150(2) 70 7/12/77 <20 <20 50 290 <20 7/18/77 <20 <20 50 350 <20 7/24/77 <20 <20 100 520 <20 7/30/77 <20 <20 30 590 <20 ------- TABLE 4-14 NEW YORK - PCI3 AIR SAMPUNG PAGE TWO Glen Falls Warrensburg Hudson Falls Fort Edward I Fort Edward II Date 5601—4 5660—02 5726—01 5755—01 5755—02 8/5/77 R <20 120 H <20 8/11/77 R <20 R R R 8/17/77 <20 <20 R 480 <20 (ii D l 560 1—04 = Continuous Air Monitoring Station, Glens Falls 5660—02 = DEC Region 5 Suboffice, Warrensburg 5726—01 = Main Street School. Hudson Falls 5755—01 Washington County Office Building, Fort Edward 5755-02 = Fort Hudson Nursing Home, Fort Edward H Reject LA. = Lab Accident STB Sampling Train Broken NH = Not Run Less Than > = Greater Than (1) = Appear to have been switched but can’t be verified (2) Results are inconsistent with each other: 5726—01 is usually ten percent of 5755—01. Source: NYSDEC Division of Air Resources. 1977. General Electric PCB Study — Fort Edward area (weekly laboratory reports). As reprinted in: ‘Malcolm Pirnie, inc., January. 1978. ------- TABLE 4-15 SUMMARY TABULATION OF AIR PCB DATA BY NYSDEC DIV. OF AIR RESOURCES (Data taken at Temperature of 65—85°F) Air PCB Sediment Ratio Site Comment i nii _pfl / Air/sediment Reference Caputo Dump Max. 300 10,000—50.000 Dr. Hawley Caputo Ave. 130 10,000-50,000 0043 2/26/79 memo and original Air Resource Data Ft. Miller Dump Max. 35 5.000—15,000 Ave. 24 5,000—15,000 .0024 Remnant Area Max. 10 1,000—2.000 Ave. 9 1,000—2,000 .006 Moreau site with excavated 3A material Max. 15 600—1 .000 Ave. 5.6 600—1,000 .007 Buoy 212 SIte On sample Summer 1979 85 F 0.7 50100 .0093 Summer 1979 Air Resources Data Old Moreau Site Summer 1979 Ave. 0.3 20—50 .0085 Summer 1979 Air Resources Data Source: DEIS. 1981 ------- An early paper (Hullar, et al., 1976) reported data gathered from 1972 to 1975 which showed that Hudson River fish contained the highest known PCB concentrations within the United States. The report also indicated that PCB contamination in fish decreased regularly with distance below Thompson Island. A second report by Spagnoli and Skinner (1977) summarizes the results of a state- wide survey which showed that edible fish flesh from the Hudson River frequently contained wet—weight—basis PCB concentrations of 50 ppm or more and that concentrations up to 599 ppm could be found In the larger oil—rich species. A survey of Spagnoll and Skinners data revealed that between Fort Edward. New York. and Waterford, New York. not a single member of the species studied exhibited an average PCB concentration less than the FDA temporary limit of 5 ppm (wet weight basis), and although the average concentrations appeared to decline with distance downstream, concentrations exceeding the limit could still be found below the Federal Dam at Troy, New York. Migrant marine species, such as American eel and striped bass, appeared to be especially susceptible to PCB contamination in the Lower Hudson estuary. The New York State Bureau of Fish and Wildlife inferred temporal trends of PCB contamination in fish between 1976 and 1981 by collecting specimens from specific locations during the same annual time frame (Armstrong and Sloan,-1981; Sloan and Armstrong, 1981). In these studies it was discovered that lipid content rather than size or age was the primary factor determining PCB contamination. This relationship apparently confirmed that the aquatic biota was under the influence of a homogeneous, unidirectional flux of PCB. In order to provide meaningful trends for evaluation, analytical PCB levels based on wet tissue were converted to PCB concentration per unit—weight of lipid in individual fish. The results of these studies are discussed below. Table 4—16 summarIzes the Armstrong and Sloan data for fresh—water resident species collected from the river reach between Fort Edward and Catskill, New York. Fresh—water species showed an overall annual decline in total PCB content of 34.0 + 12.6% for the interval between 1977 and 1980. This decline was due almost entirely to decreases in Aroclor 1016, which showed an average annual 4—57 ------- UPID-BASED AND WET-WEIGHT-BASIS PCB CONCENTRATIONS IN FRESH WATER RESIDENT FISH SPECIES Lipid—based PCB (ppm) Total PCB AROCLOR AROCLOR Total Location Species Year ( ppm, wet) 1016 1254 _____________ StUiwatar Drown Bullhead 1977 106.5+49.2 1908+799 388+253 2508+1.056 1979 8.97+12.26 734+359 589+567 1336+854 1980 12.34+6.56 694+190 750+290 1479+466 Goldfish 1977 559.4+506.8 3961+3065 589+467 5255+3700 1978 273.6+237.4 2684+1278 565+330 3571+1645 1980 72.62+55.42 537+326 660+424 1206+654 Largemouth Bess 1977 70.72+62.04 4470+1589 1114+333 6010+2020 1978 153.08+81.57 3135+1175 915+413 4318+1588 1980 10.44+13.83 840+347 868+379 1735+722 (1 Yellow Perch 1977 12.60+8.85 2555+1295 851+353 3725+1690 1980 0.84+0.60 450+171 507+272 957+420 Albany/Troy Brown Bullhead 1977 37.90+27.90 676+422 185+115 904+511 1978 25.16+10.46 359+117 101+38 515+146 1979 7.15+9.20 169+88 136+75 306+139 1980 2.09+1.66 96+63 88+64 206+135 White Perch 1977 118.4+73.2 1066+840 182+146 1365+976 1978 85.4+41.1 715+187 171+87 948+229 1980 16.04+9.87 122+72 182÷91 316+129 Catskill Largemouth Bass 1977 29.56+19.33 1732+959 671+500 2436+1170 1978 28.96+21.17 1034+649 539+450 1600+1056 1980 1.08+0.69 119+76 183+133 350+223 Redbreast Sunfish 1978 4.08+2.42 247+132 195+117 458+231 1980 2.63+5.51 98+70 223+170 380+287 Yellow Perch 1977 4.58+3.19 1080+741 367+334 1497+1081 1980 0.54+0.31 67+75 164+141 277+168 Source: Armstrong an Sloan, 1981 ------- decline of 147.3+ 10.0%, convertible to an approximate half—life value of 1.15 0.38 years. De, ,clines in the more highly chlorinated homologs (Aroclor 1254) were less extensive, approximately 6.8 17.5%. In some species——brown bullhead, goldfish. and redbreast sunfish——a small but signIficant increase in Aroclor 1254 was noted. The authors concluded that the heavier PCB homoiogs continued to contaminate fish flesh at rates roughly equivalent to those present years ago. The moderate decline in Arocior 1254 content was attributed to the higher stability of the compound relative to the lower chlorinated Aroclors, although the authors acknowledged that difficulties with anal ’ticai interpretation of Aroclor mixtures and possible secondary point sources may have been affecting the trends. In 1982 monitoring data showed that lipid—based PCB concentrations in fresh water species had continued to drop. Mean PCB concentrations in brown bullhead, goldfish, and largemouth bass had reached 428, 310, and 1000 ppm, respectively (Brown and Werner, 1983), an overall decline of almost 90 percent since 1977. The temporal and spatial trends of PCB in migrant marine species were not as obvious because of their complex life histories. For instance, some species, such as rainbow, smelt, blueback herring, alewife, and American Shad, enter the river only to spawn and do not feed there. In such cases PCB contamination occurs principally by diffusion so relationships between PCB content and lipid content, or size, age, or sex, are -not as clear. In other species having both migrant and resident pop ilations, such as striped bass, trends are difficult to follow. Nevertheless, there have been notable decreases in total PCB content in all salt- water species since 1977. Sloan and Armstrong’s data for migrant marine species are summarized in Table 4—17. The overall annual decline for total PCB was 28 percent between 1977 and 1980. Most of the decline in PCBs was due to reductions in Aroclor 1016 just as it was for fresh—water fish (42 percent). The average annual decline in Aroclor 1254 was only 5 percent. 4-59 ------- TABlE 4-17 LIPID-BASED AND WET-WEIGHT-BASIS PCB CONCENTRATIONS IN MARINE SPECIES PCB (ppm) wet basis Total PCB Location Species Year Total ARO1O16 AR01254 ( ppm)—ilpld basis Below Newburgh Blue Claw Crab—Muscle 1976 <0.75 —— 204 Blue Claw Brab—Muscle 1979 <0.50 + 0.45 <0.10 + 0.002 0.34 +0.44 179 + 115 - — Hepatopancrease 6.70 + 5.49 0.71 + 0.56 5.91 ± 5.06 152 + 70 Atlantic Sturgeon IndIan Pt. — immature 1980 2.80 + 2.02 0.65 + 0.66 2.06 + 1.55 280 1- 391 Catskill — adult 1981 4.96 <0.20 4.76 3 •5 Shortnose Sturgeon IndIan Pt. — fIllet 1980 1.83 0.19 1.54 165 — liver 7.10 0.67 6.33 122 29.6 2.62 25.9 148 Mohawk B. Blueback HerrIng 1979 2.50 + 0.95 106 ÷ 0.47 1.34 + 0.60 75.1 + 39.4 (lock 7) 1978 3.91 1 78 1.67 49.9 Albanv/Trov 1980 1.81 0.72 0.95 32.3 Albanyulroy Alewife 1978 5.64 3.73 1.40 109 1979 3.98 + 1.28 1.77 + O 65 1.67 + 0.51 50.1 + 11.8 Catskill 1979 2.16 ± 0.99 0.66 + 0.57 1.35 ± 0.56 45.0 + 39.9 Saugertone 1979 2.41 ± 1.47 0.76 ± 0.58 1.40 + 0.71 44.0 ± 18.2 Kingston 1979 2.50± 1.04 0.69 ± 0.45 1.71 ± 0.84 31.7 + 12.8 1980 3.02 0.70 2.22 32.8 Newburgh 1979 2.60 + 1.12 0.61 + 0.44 1.84 + 0.73 33.8 + 13.6 ------- TABLE 4-17 PCB CONCENTRATIONS IN MARINE SPECIES PAGE TWO PCB (ppm) wet basis Total ARO1O16 __________ Total PCB AR O 1254 ( ppm)-lipid basis Albany/TroV American Shad 1980 1.72 ± 1.52 0.96 + 1.04 0.63 ± 0.44 26.6 ± - male — female — female — male — female 1980 2.38 ± 1.02 0.92 + 0.35 1978 1980 2.23 + 1.16 2.98 1.22 ÷ 0.79 0.95 + 0.50 0.21 + 0.12 1.05 ± 0.47 0.52 + 0.21 0.61 4 0.47 1.32 0.54 + 0.17 20.3 + 103 10.4 ± 5.8 15.4 + 9.6 27.5 10.5 + 6.7 Location Species Year 0 ) -a Catskill Poughkeepsle Peekskil l Tappan Zee Bridge — male 1977 7.04 ± 2.88 - female 5.51 + 2.23 - male 4/20/78 3.98 + 1.90 - female 1.66 + 0.86 - male 5/5/78 4.21 ± 1.79 — female 1.63 + 0.77 — female 5/16/78 3.25 + 2.46 — male 5/9/00 2.46 + 1.21 — female 1.20 + 0.41 2.89 0.90 2.03 1.06 2.15 1.02 0.36 + + + + + + + 1.54 0.59 1.50 0.55 1.92 0.79 0.28 0.85 0.53 0.90 0.36 0.79 1.16 0.64 + + + + + + 4 0.46 0.30 0 50 0.23 0.48 0.61 0.23 24.2 + 10.6 12.4 + 5.7 20.7 + 9.2 8.6 ÷ 40 17.3 ! 7.1 19.4 + 15.1 12.0 + 7.2 1.19 ± 0.74 1.36 0.22 + 0.18 — male — male — female — male — female — male — female — male — female 1977 4/13/78 5/12/78 1979 1980 3.55 3.28 2.73 3.18 1.46 1.54 1.17 1.93 1.22 ± 1.11 + 2.13 ± 5.44 ± 1.83 + 0.48 + 0.68 ± 0.44 1.09 + 0.67 2.14 1.23 1.89 049 0.71 0.37 0.75 0.33 + 1.73 ± 2.71 + 1.51 0.37 ± 0.33 ± 0.11 + 0.51 + 0.29 0.67 1.14 ± 0.88 ± 0.60 ± 0.84 ± 0.80 ± 0.83 0.63 ± 0.37 2.62 0.43 0.12 0.40 0.35 0.47 0.33 10.1 ± 12.1 19.2 ± 28.8 17.9 ± 8.6 10.4 ÷ 3.4 8.7 + 4.1 7.0 ÷ 2.1 16.3 11.1 10.1 + 4.9 ------- TABLE 4—17 PCu CONCENTRATIONS IN MARINE SPECIES PAGE THREE Poughkeepsie Indian Point Haverstraw Ray Riverwide Year 1981 1981 1978 1980 1981 1980 1980 1980 1980 1979 1979 1980 1980 1979 1980 1977 1980 1978 1980 1981 1979 Totat 13.1 ÷ 11.81 10.70 0- 9.68 73.9 :!: 66.7 9.07 + 8.61 10.83 ± 6.22 8.15 + 4.30 5.89 + 2.50 6.76 -I- 12.89 7.13 ± 8.73 4.07 ± 2.34 4.51 ± 2.78 4.33 2.36 + 0.31 0.46 ± 0.35 0.66 + 0.21 0.96 + 0.74 10.37 ± 0.08 18.10 + 28.22 6.13 ! 7.43 4.81 + 5.98 3.15 ± 1.74 PCB (ppm) wet basis ARO1O16 0.93 + 0.56 0.73 4. 0.66 39.9 + 41.6 0.46 + 0.29 0.49 ± 0.33 0.53 ± 0.23 0.38 + 0.19 0.22 + 0.14 0.44 + 0.32 1.31 ± 0.75 1.32 4- 0.79 1.22 0.65 ± 0.27 0.22 + 0.24 0.25 + 009 0.65 + 0.55 10.14 1- 0.05 9.64 ± 18.32 1.68 + 2.95 1.02 + 2.20 0.62 + 0.31 ARO 1254 12.24 4- 11.46 9.85 + 9.08 33.2 + 28.6 8.51 ± 8.25 10.23 ± 5.97 7.52 ± 4.10 5.41 ± 2.33 6.44 -0- 12.79 6.57 ± 8.52 2.64 ± 1.59 3.10 :!: 1.93 3.01 1.61 ± 0.12 0.14 + 0.11 0.31 ± 0.13 0.21 + 0.20 10.13 + 0.05 7.70 10.34 4.28 + 4.83 3.50 ± 3.94 2.43 ± 1.48 Total PCB ( ppm)-Ilpid basis 129 + 134 184 + 333 612 ± 418 190 + 64 109 4- 79 71.0 ± 13.8 66.0 ± 23.9 98.4 ± 87.8 78.2 ± 55.2 184 .1 70.6 213 ± 89.3 185 121 + 17.7 246 87.7 119 + 34.3 166 ± 81.4 86.8 ± 40.1 270.24 + 417.95 168.38 + 144.13 152.00 186.29 227 ± 84.0 Species Location Poughkeepsie American eel Peekski li Indian Point - Nyack Pier 40 (NYC) Verrazano Bridge i’, Queensboro Bridge Kingston Rainbow Smelt Newburgh Atlantic tomcod Striped Bass Bluefish Peekskiii Source: Sloan and Armstrong 1981 ------- The authors cautioned that the new decreases could be artificial since the study was carried out during a period of exceptionally stable river flows and, therefore, the data did not reflect possible responses to increased PCBs in the water column occurring during extreme flood conditions. They also pointed out that PCB concentrations in fish should not continue to substantially decline under present conditions because of the depletion of Aroclor 1016. In conclusion, the authors state that even with the declining trend, most fresh—water species contained PCB contamination exceeding the FDA—recommended limit and that current contamination (Table 4—18) in marine species is well above background levels. Brown and Werner (1983) caution that due to the distribution of various—sized fish in annual samples and the positive correlations between fish length or weight and PCB concentrations. PCB contamination on a wet—weight basis Is skewed to the low end of the distribution. Therefore the arithmetic means shown in the tables (for wet—weight concentrations only) are considerably higher than either the median value or the log o mean PCB concentration. Brown and Werner also argue that because large flood events In the tipper Hudson River are infrequent, It is the low—flow water column PCB concentrations which control fish contamination. Because of this, large floods will Increase PCB concentrations in fish flesh only If scour exposes more highly contaminated sediments at the sediment—water—interface. They further point out that PCB—laden suspended sediment is likely to control fish contamination in the Lower Hudson because of the long residence time of flood peaks in the estuary. 4.1.4.2 Invertebrates In 1981, the NYSDEC Division of Water Research studied PCB in the fresh water clam Elliptio complanatus in connection with DOT dredging in contaminated sediments (NYSDEC, 1981b). Clean sets of clams were exposed both upstream and downstream of the dredge site and a third set of clams was maintained upstream of Glen Falls as a control. 4—63 ------- TABLE 4-18 CURRENT APPROXIMATE AVERAGE TOTAL PCB CONCENTRATIONS IN HUDSON RIVER MIGRANT/MARINE FISH (WET BASIS) ENCOUNTERED BELOW TROY Year Approximate Average __________________________ Analyzed _ CB (ppm) Value Blue Claw Crab—Muscle 1979 <1 hepatopancreas >5 Atlantic Sturgeon—immature 1980 2—5 — adult 1981 p5(a) Shortnose Sturgeon 1980 < 2 (b) Blueback Herring 1980 2—5 Alewife 1980 2—5 American Shad 1980 1—3 American Eel 1981 Ji0 Rainbow Smelt 1980 3—5 Atlantic Tomcad 1980 <1 Striped Bass 1981 Bluefish—Immature 1979 t3 (a) Only one analyzed. (b) Endangered species; possession is prohibited. Less than Greater than — Approximately Source: Sloan and Armstrong, 1981 4-64 ------- After a two—week exposure, the dredge site clams had accumulated an average lipid—based PCB concentration of 75.5 ppm compared to 6.0 ppm in the control sample. After a 2—week depurification period the PCB concentration in the contaminated clams decreased to an average of 12.4 ppm, and the corresponding value in the control sample dropped to less than 0.02 ppm. There did not appear to be a significant difference in the PCB concentrations between contaminated clams above or below the dredge site. Results of a Department of Health freshwater macroinvertebrate study appear in a NYSDEC Report (NYSDEC. 1982). This study Included PCB analyses of a number of aquatic Insects in the Upper Hudson, the Lower Hudson. and above Glens Falls. The results for caddis fly larva, the most frequently sampled. species, are reported below. In the control area (above Glens Falls), PCB concentration on a dry—weight basis averaged less than 5.3 ppm between 1979 and 1981. The average PCB content of the insect in the Upper Hudson reach dropped from a high of 50.14 ppm in 1979 to 27.59 ppm inl9BO. In 1981 the PCB content of the species In the reach rose slightly to 28.57 ppm. PCB contamination of the caddis fly was less in the Lower Hudson reach, dropping from 21.66 ppm to 11.60 ppm between 1980 and 1981. This decreasing trend is consistent with that observed in fish over the same period. A number of PCB analyses for blue claw crabs, the only marine invertebrate to be studied, appear for 1979 samples in NYSDEC Technical Report No. 81—1 (1981). Results show PCB concentrations both for muscle tissue and for the hepatopancreas, which Is consumed by many local people as a delicacy (Sloan and Armstrong, 1981). PCB contamination in muscle tissue is relatively low, ranging from less than 0.34 to less than 0.40 ppm on a lipid—based measure for various areas. Contamination of the hepatopancreas, however, is more serious, with PCB concentrations ranging from an average of 9.64 ppm at Foundry Cove to a low of 4.62 ppm at Havestraw Bay. Concentrations as high as 20.21 ppm were found in hepatopancreas tissues. These values, however, represented a substantial reduction in PCB since 1976 (Armstrong and Sloan, 1980, 1981). 4—65 ------- 4.1.4.3 VegetatIon In 1977, Weston, Inc., documented the presence of PCB contamination in plants around PCB dumps and dredge spoil sites of the Upper Hudson River. PCB levels of up to ‘2800 ppm were found in the leaves of plant species growing on PCB dumps, while undetectable concentrations were generally found in plants from other areas (NYSDEC, 1981). Boyce Thompson Institute later determined that measurable PCB accumulations In foliage extended as far as 700 to 1000 meters from highly contaminated local sources. The following table presents measured PCB content of leaves of trembling aspen, as determined along an easterly transect from the Fort Miller dump site, and the considerably lower levels of PCB content found in aspen leaves east of Buoy 212 dredge spoil site and east of a riffle area in the Hudson River near Lock 6. it must be noted, however, that PCB uptake varies markedly among different plant species (NYSDEC. 1981). PCB content in trembling aspen leaves ( Populus tremuloides Mlchx..) along easterly transects from three local sources of volatile PCBs, the Fort Miller dump site, the Buoy 212 dredge spoil site, and a Hudson River riffle area near Lock 6, Fort Miller, New York, is as follows: Dump Site Dredge Site Riffle Area Distance Content DIstance Content Distance Content ( ml ( ppm) ( ml ( ppm) ( m) ( ppm ) on sIte 180 on site 2.52 on site N.A. 41 - 6.58 30 0.89 10 1.26 55 4.18 50 0.44 40 0.45 92 1.96 110 0.26 450 0.11 148 0.90 400 0.19 1500 0.12 250 0.54 700 0.18 370 0.26 1300 0.17 530 0.25 2300 0.10 820 0.15 960 0.13 1600 0.12 4—66 ------- 4.2 Adequacy of Existing Data Base The data base on PCB contamination of sediments, water, air, and biota of the Hudson River area is quite extensive. In addition, substantial research into sediment PCB transport and PCB contaminant trends has been performed; yet after 5 years of study and the expenditure of more than $7 million dollars, there are still important questions and deficiencies which must be addressed. 4.2.1 Remnant Deposits The extent of the contamination in the remnant deposits Is known only through approximately two dozen core samples. PCB mass estimates for these areas vary from 45,000 to 150,000 pounds. Most of the sampling at these areas was done in 1978. No recent data documenting the amount or distribution of PCB in these deposits is available. Current information on river hydrology as it relates to remnant deposit scour appears to indicate that most remnant deposits are adequately protected from flows up to the 100—year flood stage. A comparison between aerial photographs between 1978 and 1983 reveals that massive erosion at remnant site 1 may have occurred. However, this site is an isolated Island with a low PCB content and it may not be contributing much PCB to the river. Sampling should be done to confirm this conclusion. 4.2.2 Sediment The present understanding of PCB distributions 1n submerged sediment comes from a single comprehensive analytical survey completed In 1977 and 1978. This survey consisted of approximately 700 PCB analyses from 1200 core and grab samples taken along cross—river transects which were spaced a minimum of 700 feet apart in the Thompson Island pool and farther apart south of the Thompson Island Dam. 4—67 ------- This data base has several serious problems. One problem concerns the variability of PCB contamination on the river bottom and the accuracy of hot spot delineation. Measured PCB concentrations varied widely within short distances. exhibiting almost no regionalized trends. Very high PCB concentrations were found adjacent to and In the same hot spot with concentrations less than 50 ppm. This may Indicate that hot spots are actually very localized phenomena consisting of contaminated sediments which have settled in small depressions and pockets in the river bottom. In some cases, hot spot delineations have been based on one or two high concentration samples, and intuitive assumptions on sediment deposits based on particle size distribution and river hydrology. There is a distinct possibility that delineated hot spots Contain extensive areas of sediments containing less than 50 ppm of PCB. if this is the case, then PCB mass estimates based on hot spot area and average concentrations may be extremely misleading. At this time, there is no cost—effective statistical method appropriate for estimating the degree of error involved with mapping PCB hot spots. A more serious Implication of this problem is that many small, localized hot spots may have been missed by the survey. In looking at the original survey data, about a dozen PCB concentration values which could have been Included in hot spots were ‘not. The sampling density for the 5—mile stretch of the river above the Thompson Island Dam Is low and it decreases as the distance downstream from the Ft. Edward Dam Increases. A 1983 aerial survey revealed many shallow areas which could contain hot spots that had not been heavily sampled. The possibility Is great that a substantial amount of high concentration sediments was missed while high volumes of low concentration sediments. were included in hot spots. Another problem with the survey concerns the dynamic nature of the river system and the age of the survey. A certain amount of sediment reworking is expected over the 5 years since the survey was completed, especially with the occurrence of an 80—year return period flood in May of 1983. Suspended sediment transport estimates calculated from U.S.G.S. measurements have shown that, up to 1982, the amount of PCB removed from the Upper Hudson River by suspended sediment 4-68 ------- transport over the Troy Dam has been relatively small. The amount of sediment reworking by bed—load movement in individual pools is completely unknown. Many of the more extensive contaminated deposits, especially those In the Thompson Island pool, appear to be located in unprotected high velocity areas where even during an average annual flood, flow velocities may be sufficient to cause scour. A third problem concerns the quality of PCB analysis performed on the sediments. Even today, PCB quantification is a difficult process subject to a high degree of error. Some of the methods used by the original contractors may have been faulty since information in some NYSDEC publications shows that ratios of the results of some duplicate samples were at least 1 to 3. This is a source of variation which adds to the uncertainty about the amount and concentration .of PCBs in delineated hot spots. Many of these problems were recognized by State officials, which is why they had proposed an extensive sampling survey prior to the implementation of a dredging program. However, It must be pointed out that PCB mass estimates, cleanup operations, and most other conclusions are based on hot—spot delineations and sediment PCB data, with a significant amount of uncertainty associated with it in 1977. This data Is even more uncertain in 1983. A limited sampling program was conducted in August of 1983 in the upper hot spots to try to determine whether movement of the contaminated sediments had occurred. The results and analysis of this survey can be found In Appendix E. The results showed movement in some but not all of the hot spots. They also appeared to show a decrease in the concentrations of PCBs in those hot spots sampled. 4.2.3 . Water The water—column data generated by the USGS has some minor problems which have already been mentioned. It is generally sufficient for environmental monitoring. There are, however, two important aspects of PCB water—column concentrations which have not been addressed. 4-69 ------- The first Is the amount of water—column PCB originating from hot spots and cold areas. Since highly contaminated hot spots cover only 8 percent of the river bottom, it is not known whether water column and air PCB concentrations, as well as fish contamination, will lessen significantly if hot spots are removed. The relative contribution of areas of relatively small extent with high concentrations compared to the contributions of extensive areas of moderate contamination (average 20 g/g) needs to be assessed. The second area that has not been addressed is the concentration of PCBs In water supplies. This type of data has not been provided in NYSDEC publications. 4.2.4 Air As with PCB concentrations in water, the PCB concentration In air has not been extensively studied at receptor sites. 4.2.5 Biota The data base for PCB contamination of Hudson River blota Is sufficient for Indicating trends. Some authors have questioned the validity of reporting wet— weight PCB concentrations as an arithmetic mean since wet—weight concentrations are skewed to the low end of the scale. Median values for most fish species are substantially lower than reported arithmetic averages, which means that the probability of obtaining a highly contaminated fish is much less than the arithmetic mean would indicate. However, as long as highly contaminated individual fish do exist, the public health concerns cannot be ignored 4.3 Evaluation of PCB Transport Model Mathematical models of the fate of PCBs In a natural water system can potentially cover a wide spectrum of empiricism versus theory, and simplicity versus complexity. The principal reason for such a diversity of models is that the dynamics of PCBs are governed by many disciplines in which a complete 4—70 ------- understanding of basic processes and their rates is still lacking. Hydrodynamics, chemistry, and biology represent the major sciences involved. At one extreme are attempts to incorporate available kinetic descriptions of simple systems from each discipline into one uultimate predictive model. T.he drawback of this approach Is that when models from various disciplines are interfaced, a compounding of the uncertainties of each submodel may lead to overall results in which one can have little confidence. The other extreme is the empirical approach, which could involve either a rigorous analysis of available data or a comparison of parameter values for the case under study with similar parameters for water bodies previously studied. In the empirical approach, no a priori consideration is given to the basic physical, chemical, and biological processes governing the observed responses, although the processes are often cited to explain observed trends. Almost all modeling studies lie between these two extremes, with the relative position commonly dictated by the available data base, budgetary constraints, and the imposed schedule of performance. The Hudson River model under review appears to be no exception, and thus to judge its adequacy one must carefully consider whether the selected modeling framework is consistent with the available data, modeiing objectives, and ultimate use of the results. In order to best track the reports on which this review Is based (Lawler, Matusky, and Skelly (LMS), 1978— 1979), the hydraulic, sediment transport, and PCB inventory submodels will be addressed separately in the following sections. Model selection (and/or development), calibration, and validation will provide the primary points of discussion. 4.3.1 Hydraulic Submodel The hydraulic submodei, which was provided via the generalized computer program HEC—6 (aScour and Deposition in Rivers and Reservoirs), has its basis in the computational algorithms of the computer program HEC—2 (“Water Surface Profiles”). Where applicable, these programs are widely accepted for engineering studies and have been thoroughly tested and validated in various applications over the years. 4—71 ------- Two principal technical concerns related to the direct application of the HEC hydraulic model to the Hudson River study have been identified. These include the one—dimensionality of the model, and the artificial control imposed by the locks and dams on the hydraulics of the river system. The one—dimensional limitation of the model is important In that it prohibits both a differentiation between the computed average streamfiow velocity and the local bottom velocity that is critical to the sediment—water interchange, and a resolution of lateral velocity variations that would be of value in explaining observed depositlonal patterns and assessing proposed remediation of hot spot areas. The lack of vertical resolution is directly related to the locks and dams issue, as the primary concern is whether the hydrodvnamic effects of the resultant backwater pools would negate the use of a one—dimensional model when the local bottom velocity is of ultimate importance to sediment transport. in the case of the Hudson River above the Federal Dam at Troy, the latter concern is minimized because the length of each reach (at least two miles) is large relative to the dam height (generally less than 10 feet). The significant hydrodynamic effects in the vertical direction are thus limited to river zones immediately upstream and downstream of the structures, with a large portion of each reach exhibiting velocity distributions similar to those of a free—flowing river. The Increased depth of flow created by the backwater from the dam does result in an increased cross—sectional area of flow, however, and thus a lesser velocity than would occur under natural flow conditions. This decrease in velocity represents the primary effect of the dams on the sediment transport process and is adequately treated in the HEC hydraulic algorithms (McArthur, 1983). The one—dlmensionallty of the model generally remains a technical drawback relative to a comprehensive assessment of alternatIve courses of action. Two— or three—dimensional hydrodynamic models are available within the state of current practice that could potentially generate a refined understanding of velocity profiles. However, the effective use of such models requires an extensive hydrologic and hydrographic data base that is not currently availabie for the Hudson River. in addition, a hydrodynamic modeling effort at this level of refinement would be inconsistent with the current state of modeling of the 4—72 ------- sedimentation and erosion behavior of organic and cohesive materials; that is, an interfaced modeling effort is only as reliable as its weakest component, and to go beyond the one—dimensional hydrodynamic model would not be technically or financially effective when less understood sediment transport and PCB interaction processes also play principal roles in PCB transport. Given this affirmative judgment as to the suitability of the HEC hydraulic model for the case under study, the remaining issue is model calibration. The only comparative data available in the Hudson River study report (LMS, 1978) is for the reach between Lock 7 and Thompson Island Dam. For each of the three flows tested, the water surface elevation from the model exceeded the mean observed elevation (see Figure 4—8). The primary source of these differences appears to be the rating curve (i.e., the initial condition) at the dam, since in each case the water surface elevation within the drawdown curve at the dam already exceeds the observed elevation at the upstream end of the reach. In order to assess the potential error of this level of calibration, the mean flow rate was plotted against the elevation of the observed water surface with respect to the dam crest elevation (see Figure 4—9). A relatively linear relationship Is observed on the log— log plot, as would be expected under weir flow conditions: (Note that this analysis is approximate since the observed elevations are at the upstream end of the reach. but nevertheless the linear relationship appears to be satisfied.) The respective flow rates corresponding to the water surface elevations from the model are also noted on Figure 4—9, and are observed to be consistently about 30 percent higher than measured values. Even though no documentation of the calibration was available for this review, improvement In hydraulic model performance could likely have been achieved. The eventual result of this discrepancy is that the cross— sectional area of flow for a given discharge is overestimated to a comparable degree, and in turn the resultant average velocities that drive the sediment transport model are underestimated. This observation could be Important with respect to a recommended remedial measure to modify the channel geometry in order to reduce the scour velocity. It is doubtful whether any channelization that would reduce stream velocity in excess of the perceived modeling discrepancy could be implemented, at least cost—effectively. 4-73 ------- 130 MEAN MEAN HEC 6 OBSERVED JRVEYOR .0w ( CFS) COMPUTED EVA11ON NY DEC SEP. 22, 1976 4720 o NORMANOEAU NOV. 18-22,1976 7440 A NORMANDEAU APR. 30,1977 21,000 0 128 MAY , 1977 26 - . . . — ‘--.- - 124 — U i U i 0 122 — U) Ui a — a — C — — — 120 0 118 ThOMPSON IS. - DAM CREST REF: LMS (1978) 116 I I I — 194 193 192 191 190 189 188 RIVER MILE INDEX FIGURE 4 -8 HEC-6 HYDRAULIC CALIBRATION LOCK 7 TO THOMPSON IS. DAM REACH HUDSON RIVER PCB SITE, HUDSON RIVER, N _____ 474 A Hailiburton Company ------- 44 29,000 CFS vs - 21,000CFS 4.3 — 4.2 (-LINEAR RELATIONSHIP -d BASEDONOBSERVED WATER SURFACE 4.1 ELEVATIONS. Ct) 0 z 4.0 0 -J z LiJ39 o -J 3.8 — LEGEND — 6,100 CFS vs a OBSERVED ELEVATION . MODEL ELEVATION 3.6 0.5 0.6 0.7 0.8 0.9 LOG (W.S. ELEVATION IN FEET ABOVE THE DAM CREST) FIGURE 4-9 APPROXIMATE RATING CURVE TO ILLUSTRATE DEFiCIENCIES IN HYDRAULIC SUBMODEL CALIBRATiON :I’ _ILJB HUDSON RIVER PCB SITE, HUDSON RIVER, NY ____ OORPCRA1ION 4-75 0 A Halliburton Company 10,000 CFS vs 7,440 CFS ------- 4.3.2 Sediment Transport Submodel The HEC-6 sediment transport model is Intended primarily for studies involving coarse or noncohesive sediments. Therefore, to realistically apply the model to a situation such as the Hudson River, in which organic and fine—grained cohesive materials play an important role, becomes problematical. This limitation was addressed by the model—study authors but was not considered by them to be a fatal flaw In model usage since high flow conditions corresponding to the transport of noncohesive sands were found to dominate total PCB transport. If the latter finding was Indeed the case, then the use of the model could be justified, given the lack of basic knowledge of the physical—chemical processes of organic and cohesive sediment transport, and the paucity of site—specific data. However, as will be discussed in subsequent paragraphs, there is evidence from the baseline data that suggests otherwise. In order to assess the sediment transport model, only those river sites for which data were available will be considered. Intermediate reaches for which only model results of sediment behavior are provided will be ignored since there is no field data to test the reliability of the respective results. Calibration plots of sediment load versus flow for the four points of Interest are reproduced as Figures 4—lOa through 4—lOd. At Glens Falls, a regression relationship is simply imposed onto the data to establish an initial condition for Lock 7, and as such, is Inherently an excellent fit to the data (Figure 4—lOa). The next point Is at Lock 4 (Stlllwater) and represents the model performance through the first four reaches (Figure 4—lOa). The model is observed to consistently underestimate measured sediment concentrations by an approximate factor of two at high flows and by at least an order of magnitude at low flows. This initial test of the model is extremely poor and led to a decision by the modelers to suppress the use of the model output from Lock 4 as input to the next reach. Rather, the actual field data was substituted for use as a starting condition for the remaining reaches. The primary reason given by the authors for this poor model performance was the lack of data differentiating the fractions of silts and clays that would affect low—flow predictions. However, two points are noteworthy. 4-76 ------- LEGEND / - USGS SUSPENDED SEDIMENT DATA(MAR—SEP 177) / - — — —— SUSPENDED SEDIMENT LOAD REGRESSED / TOTAL SEDIMENT LOAD IN HEC-6 •. / UPSTREAM BOUNDARY / . / / o S I — : S. S • S /1 o -J .1 S • • I— •S /.•• z w 6 LiJ C t) S I. SI’ . I. S - / • REF: LMS (1978). • / - I I I I liii I I I 111111 Il,. I J J FLOW (CFS) FiGURE 4-104 SUSPENDED AND TOTAL SEDIMENT LOAD VS FLOW - ____ HUDSON RIVER, GLENS FALLS, NY HUDSON RIVER PCB SITE, HUDSON RIVER, NY ____ cC CRA11CN Q A Haikburton Company 4-77 ------- . 1,000 10,000 FLOW (CFS) TOTAL SEDIMENT LOAD VS FLOW MODEL CALIBRATION PERIOD DEC ‘76-MAY ‘77 USGS DATA (STILLWATER)-RMI 68.5 HUDSON RIVER PCB SITE, HUDSON RIVER, NY FIGURE 4-lOB — NUE _CO AflON 0 A Haihburton Company LEGEND —0—’ “NO DEPOSITION, NO SCOUR” MODEL RESULTS HEC 6 MODEL RESULTS REGRESSED USGS DATA MAR SEP’77 e/0 OF TIME FLOW NOT EXCEEDED I . 100 ,000 101000 1 ,000 100 I0 . • S S •5 S • I S • S p 3 .1 • • S S I I. 1• I I I S S S REF LMS ( 1978) 100 0 0 ” a’ s I00,000 4—78 ------- I 0OpOO — LEGEND 10,000 — 1,000 100 I0 100 “NO DEPOSITION ,NO SCOUR” MODEL RESULTS HEC6 MODEL RESULTS - REGRESSED USGS DATA OCT ‘76 - SEP ‘77 % OF TIME FLOW NOT EXCEEDED I I. • •• I • I. • • S . S •: : I I I I I iii’I 1,000 o o 0 — 0 ’ I 11 I I ’iIIi1 I ’ 10,000 FLOW (CFS) TOTAL SEDIMENT L D VS FLOW MODEL CALIBRATION PERIOD USGS DATA (WATERFORD) - RM I FIGURE 4- IOC ±NUB I - CC CRA11CN 0 A Halliburton Company S S S I. • I S •. • S S • S • I. • S • •••• • S I •, I , S I S S S • • •• S I I I .1 REF: LMS (1978) 100,000 11 DEC’76-MAY ‘77 HUDSON RIVER PC SITE, HUDSON RIVER, NY 157.2 4—79 ------- LEGEND —Q--- “NO DEPOSITION 1 NO SCOUR” MODEL RESULTS HEC6 MODEL RESULTS - REGRESSED USGS DATA 1970 ‘-1976 04 OF TiME FLOW NOT EXCEEDED REF: LMS (1978) 0 I C , 0 . S I I I I titti I I I I I’ I t’ ! I i I I ill 100 1,000 10,000 100,000. FLOW (CFS) TOTAL SEDIMENT LOAD VS FLOW MODEL CALIBRATION PERIOD DEC ‘76- MAY ‘ 78 USGS DATA (GREEN ISLAND)—RMI 153.9 HUDSON RIVER PCB SITE, HUDSON RIVER, NY FIGURE 4-100 H NUB ______ CC R. AT)ON 0 A Halliburton Company I 100,000 I0,000 1,000 I00 I0 S . I. I ., . I S I . I V I. S I I 4—80 ------- First, the model at each intermediate reach predicted a net deposition of sediment for all flows less than the 1 percent exceedance value. This is inconsistent with field data that indicate a net increase in sediment concentration for essentially all flows, as discussed below. Second, even though the modelers recognized that the silt component reported as a single value in the data base ranged in size from 0.004 mm to 0.062 mm, they assigned all silt to the coarsest model category (0.032 mm to 0.062 mm). This contributed to the low—flow problems, and it Is questionable why this “unknown” distribution of grain size was not used as a model— fitting parameter. An alternative test of model performance Is to compare the suspended sedIment data at Lock 4 with the results of a simple model that assumes that neither deposition nor scour is occurring between Lock 7 and Lock 4. Under this assumption, the concentration of suspended sediment at Locks 7 and 4 would remain constant for a given frequency of flow, and the total suspended sediment load would be proportional to the flow rate (under the assumption that all inflow between the two points, as approximated by drainage area scaling, enters with the same concentration as occurred at Lock 7). The results of this simple “no deposition, no scour” model are also shown in Figure 4—lOb. The results satisfactorily follow the trend of the data, but even in this case the observed sediment load is underestimated. This indicates that either significant scour Is occurring or else tributary inflows are relatively high in suspended sediment due, for example, to local variations in erosion factors such as soil type or vegetative cover. This raises serious doubts about the HEC—6 model that predicts sediment deposition throughout the reaches between Lock 7 and Lock 4. The HEC—6 model appears to perform more reliably between Lock 4 and Lock 1 (Waterford), but even in This case the model develops problems below the 50 percent flow value (Figure 4—lOc). A better fit is achieved by an extension of the simple “no deposition, no scour” model from Lock 4 to Lock 1. The results shown in Figure 4—lOc for the simple model are based on the curve at Locl 4 that underestimated sediment loads at that point, and as such even a better fit could be achieved at Lock 1 If the actual field data from Lock 4 was used, as was done in the H C—6 model. The reason that the HEC—6 model performs well at the higher 4—81 ------- flows Is that the shallower reaches between Lock 4 and Lock 1 produced higher velocities that inhibited deposition for flows greater than 10,000 cfs. Both the HEC—6 and “no deposition, no scour” models are shown to perform well between Lock 1 and Green Island (Figure 4—lOd). The primary reason for this result Is that the Mohawk River contributes a large percentage of the sediment load, and actual field data rather than model predictions were utilized to account for this contribution. For example, the sediment load at the 99 percent flow value Increased fivefold, from 2,000 pounds/day at Lock 1 to almost 10,000 pounds/day at Troy Dam, due primarily to the sediment input from the Mohawk River. Consequently, the final model results at Green island are relatively Insensitive to upstream model results and do not provide a good test of HEC—6 model reliability. in general, the HEC—6 sediment transport submodel, as utilized In the Hudson River study, appears to have overstated the importance of the deposition and scour processes to net sediment transport. A model based solely on an assumption of Tho deposition and no scour” is shown to perform more reliably. To further Illustrate this point, sediment data reported in the earlier modeling study (LMS, 1978) have been corrected for increasing downstream flow (under the assumption of constant sediment concentration in all inflows) and are plotted on Figure 4—11. Also included Is the “best fit” line for 1978—1979 data from Rogers Island, as reported in the 1979 LMS reference. (Note that 1978—1979 data for other sites were not provided in LMS, 1979, but a statement was made that the more recent data conformed to the earlier data plotted on Figure 4—11.) it is observed that the measured sediment load Is conserved between Glens Fails and Rogers island, approximately doubles prior to reaching Lock 4 (possibly as a result of unstable sediment deposits in the Thompson Island pool), and then agaIn is conserved between Lock 4 and Lock 1. Becau e the overall sediment budgets predicted by the HEC—6 model were not consistent with even this observed regional pattern, concern must be expressed as to the reliability of model predictions related to very localized deposition and scour patterns within the reaches. For example, to place 4—82 ------- 0 0 0 0 0 00 Io0po0 LEGEND — £ —••— GLENS FALL.S0977) O — — S11LLWATER (1977) o WATERFORD( 1976-1977) — ROGERS ISLAND (LMS;1979) I0pO0 I,000 100 Jo. — ________________ 100 0 0 0 0 0 0 0 £ O 000 A ‘I 00 0 0 £ 0 0 £ 0 £ 0 0 0 £ £0 0 Oô I I I 1 I itil 1000 0 a I 1111111 REF LMS (1978) I I I I iiii PLOW (CFS) 10,000 COMPARISON OF RELATIONSHIPS AT 100,900 HUDSON RIVER PCB SITE, HUDSON SEDIMENT LOAD VS FLOW VARIOLS MONITORING STATiONS RIVER. NY FiGURE 4 -Il NUB _ RATCN 0 A Hailiburton Comparry’ 4-83 ------- significance on model results that indicate net deposits of tenths of a foot within the Thompson Island pool is meaningless when field data indicate both a general increase In resuspended sediment load in the water column and spatial variations of several feet in bed elevations within the pool. A more serious concern of poor model performance Is that the predicted sediment loads represent a principal forcing function for the PCB inventory model and consequent recommendations for future actions, which are addressed in the next section. It is noteworthy that an update of the Hudson River PCB model was provided in 1979 (L.MS, 1979). However, most of the reported recalibration appears to have involved the PCB submodel, and no update or revisions to the sediment transport submodel were documented. 4.3.3 PCB Inventory Submodel The PCB inventory submodel represents a simple mass balance approach that, in theory, is appropriate to the Hudson River problem under study. However, because adequate data are not available to empirically define the principal forcing functions under all current and future scenarios, the ultimate performance of the PCB submodel is highly dependent on both the reliability of output from an independent mathematical model of the governing physical process (i.e., the sediment transport submodel) and a proper interpretation of available PCB data. The performance of the sediment transport submodel has already been discussed in the previous se tIon. In the following paragraphs, the data used as input to the PCB submodel will be assessed. These include the PCB concentration in the suspended material that forms the bed of each reach, and the initial PCB versus flow rate relationship that provides an upstream boundary condition. A general discussion of the overall impacts on the conclusions and recommendations of the modeling study will then be presented. 4-84 ------- An assessment of the input data on PCBs in bed sediments is made difficult by the widespread variation of PCB concentration in the lateral, longitudinal, and even vertical directions. However, results of the PCB submodel presented in LMS, 1978 and 1979, indicate that any errors introduced into the model by a lack of data on bed sediments would not significantly alter the overall modeling study results. For example, the predicted PCB load versus flow rate relationship at each station closely parallels the results of the sediment transport model. This indicates that it is the physical transport of PCB—laden sediments that dominates model results rather than local variations in the concentration of PCBs in the deposits on coured sediments. It is also indicated that the suspended material being transported across the upstream boundary represents a large percentage of the PCBs being accounted for in the mass conservation model within each reach. The PCB versus flow relationship would, therefore, be a more critical input factor than PCBs in the bed sediments. The initial modeling effort reported in the 1978 LMS reference utilized four data points relating PCB concentration to flow at Fort Edward to establish the upstream boundary condition. The available data points, which included only flows greater than 8,000 cfs, exhibited a definite trend of decreasing PCB concentration with decreasing flow. A linear regression relationship (on a log—log basis) for these data points was extrapolated to other lower and higher flow values to comprehensively treat the range of flows under consideration. It is now recognized that PCB concentrations do not continue to decrease for decreasing flows in the intermediate and low—flow range. In fact, PCB concentration begins to increase with decreasing flows within the low flow range. In retrospect, the adopted PCB versus flow relationship introduced serious errors into intermediate and low—flow model results, as for example at Stillwater (Figure 4—12). ThIs modeling deficiency was aggravated by the previously discussed underestimation of sediment loads. As a result, an empIrical low—flow correction was eventually imposed on the model output at Green Island. At the time of the earlier study, the low and Intermediate flow results were not considered to be a significant shortcoming of the model since the overall transport of PCBs was thought to be dominated by high flow eveiits. Nevertheless, as more 4-85 ------- 10.0 PCB MODEL RESULTS REGRE ED USGS DATA JUL -SEPT 1977 USGS TA MAR -JUNE 1977 % OF TiME FLOW NOT EXCEEDED tOO 500 l O0O 5,000 101000 50,000 lOO O0 FLOW (CFS) PCS WATER COLUMN CONCENTRATION VS FLOW COMPARISON: MODEL PCB RESULTS USGS DATA MODEL CALIBRATION PERIOD DEC ‘76-MAY ‘77 USGS D A (ST1LLWATER) RMI 68.5 HUDSON RIVER PCB SITE, HUDSON RIVER, NY FIGURE 4-12 Q A Halliburton Company REF LMS (1978) 1.0 0 A A A d A 0 0 0 A 0.1 0 0 LEGEND 0 A 00 0.0t 0 0 i 0) 4—86 ------- data on PCB concentration at low and intermediate flows became available at Rogers Island, a recalibration of the upstream boundary condition was performed (LMS, 1979). This provided a much more satisfactory fit to the PCB concentration data, as exemplified by the Stiliwater data (Figure 4—13). The critical output of the PCB inventory submodel is the current and projected PCB load over the Federal Dam at Troy. Based on the model results shown In Figure 4—14, the study estimated that an average of 6,500 pounds of PCB per year passes over the dam at Troy, with only a few percent of this total due to flows which occur about 80 percent of the time (i.e., flows less than 20,000 cfs). The low—flow correction adds 1,500 pounds per year to the total, resulting in 23 percent of all PCB flux due to flows less than 20,000 cfs. Because no field data on PCBs exist at Troy, a direct evaluation of these model projections is prohibited. However, model results indicate that the PCB load passing Troy Dam is approximately equal to the load passing Waterford for each flow—frequency value, which is consistent with the assumption of no significant PCB contribution from the Mohawk River. Under this scenario, the validity of the model at Troy should mirror the validity of the model at Waterford for which field data exist. Figure 4—15 presents both the results of the PCB inventory model and a best—fit regression line through the available data at Waterford. The figure shows that the model overestimates PCB loads by almost an order of magnitude at high flows, with an even more serious underestimation of loads at low flows. This introduces considerable error into the model projections at Troy Dam, as illustrated by a comparison of the model results in Figure 4—14 to the load curve corresponding to the best—fit regression line at Waterford. The introduction of the low—flow correction achieves a better fit, but the resultant model still overestimates both the total contribution of PCBs to the lower estuary and the proportion of the load carried by high flows. Field data generally support neither conclusion that the total PCB load nor the distribution of this load among flow ranges is adequately predicted by the PCB transport model. For example, the U.S. Geological Survey has estimated a total PCB load of 3,740 pounds passing 4—87 ------- 100 a PC9 MODEL RESULTS REMNANT POOL DEPOSITS MITIGATION (POST 1978) I 0 0 / 0 / 0/ I • 10 : - a • \.? 1 / - 1 a U — \. 0 U 0 a A0 LEGEN b • USGS DATA JUL - SEPT !977 C 0 00 o USGS DATA MAR - JUN 1977 0 C USGS DATA SEP 1977 - JUN 1978 I USGS DATA JUL - SEP 1978 USGS DATA OCT 1978 APR 1979 * % OF TiME FLOW NOT EXCEEDED REF: LMS (1979) 0 0 o — - C ., O 111111 I 4 11111 • lOG 500 1,000 5,000 10,000 50,000 100,000 FLOW (CFS) PCB WATER COLUMN CONCENTRATION VS FLOW COMPARISON: PCB MODEL RESULTS & USGS DATA FIGURE 4 13 LOCK 4 USGS DATA (STILLWATER) RMI 168.5 I ____ HUDSON RIVER PCB SITE, HUDSON RIVER, NY I 1 —P R flCN 4-88 0 A Haltiburton Company ------- CONSERVATIVE LOW PLOW ADJUSTMENT 20 40 120 140 GREEN ISLAND FLOW (CFS) x OOO FIGURE 4-14 GREEN ISLAND, PCB LOAD VS FLOW MODEL CALIBRATION PERIOD DEC ‘76-MAY ‘ 77 HUDSON RIVER PCB SITE, HUDSON RIVER, NY 0 A Hailiburton Company OoO 1 ,000 100 10 >. C l , -J 0 S 0 0 z -J U, w w LEGE ND .. MODEL RESULTS BASED ON USGS AT WATER FORD PCB MODEL F 9ITS F P SSED —— — — a — 1 /e OF TiME FLOW EXC DED NOT 0.1 0 F: LMS (1978) 60 80 100 4—89 ------- I,000 (00 I0 (00 500 1,000 5,000 10,000 50,000 (00,000 FLOW (CFS) TOTAL PCB LOAD VS FLOW COMPARISON: PCB MODEL RESULTS & USGS DATA FIGURE 4-15 MODEL CALIBRATION PERIOD DEC ‘ 76— MAY ‘77 USGS DATA (WATERFORD) RMI 157.2 j j J _fl HUDSON RIVER PC8 SiTE, HUDSON RIVER, NY ____ GO1 OF ATcN 0 A Hailiburton Company LEGEND A. 0 4, PC8 MODEL RESULTS USGS DATA REGRESSED USGS DATA JUL-SEP,1977 USGS DATA MAR-JUN,1977 % OF TIME FI..OW NOT EXCEEDED 0 0/I I I 8 a A A A 0 0 A 0 A REF: LMS (1978) I I I i Li I i1 0 20 0 I 4 a’ I I i ui 4—90 ------- Waterford during the 1977 water year (Turk. Troutman, 1981), a year In which the expected 4 percent exceedance flow of 20,000 cfs (600 m 3 /sec) was actually exceeded on 28 days (8 percent exceedance). This load is approximately half of the average annual load predicted by the model using the low—flow correction. It is of Interest at this point to consider the simple no deposition, no scour model in relation to PCB load data. Recall that this model provided a satisfactory fit to observed sediment loads throughout the study area, with the exception of underestimating the load at Lock 4 (Stillwater). Under the assumption that tributary and lateral inflows do not contribute significant quantities of PCB to the Hudson River system, two conditions would test the reliabilIty of the model. These are: 1. The overall mass rate of flow of PCBs (i.e., the PCB load) should remain essentially constant at each monitoring station for the respective flow frequency values. 2. PCB concentration should decrease approximately in proportion to river flow (I.e., to drainage area) as one proceeds downstream, or alternatively, for purposes of this study, the PCB concentrations should remain constant if corrected by drainage area scaling. Figure 4—16 presents all PCB—load data reported in Lawler, Matusky, and Skelly (1978) for the period November 1975 to September 1977. Figure 4—17 depicts PCB concentration data for the same period, while Figure 4—18 presents all PCB concentration data reported in Lawler, Matusky, and Skeily (1979) for the period October 1977 to April 1979. With few exceptions, all the data from the various stations follow the same trend and can be considered indistinguishable within the scatter of the data. The exceptions are high PCB concentrations and loads at Fort Edward (Figures 4—16 and 4—17), and particularly low values of PCB concentration at Rogers Island (Figure 4—18). Since only the Fort Edward data are from the 1975— 4—91 ------- 100 • S S I S. 5 •1 10 •S h1 .. I I I I LEGEND • FORT W RD (‘75 -‘76) • WATERFORD (‘76-’77) • ST1LLWATER (1977) REF: LMS (1978) 0.1 1 1111111 ii iiiil r i,I,,ii 00 500 1,000 5,000 10,000 50,000 100,000 FLOW (CFS) COMPARISON OF TOTAL PCB LOAD ‘ VS FLOW FIGURE 4-16 AT VARIOUS MONITORING STATIONS ( OCTOBER, 1975-SEPTEMBER, 1977 ) ___ HUDSON RIVER PCB SITE, HUDSON RIVER, NY ____ CC POP flON 0 A Hailiburton Company 4-92 ------- IC — REF: LMS (1978) 6 • ••6. LO & £ •6 £ 6 a_ ••m U a- £ . o a U a- £6 S • • 0i — LEGEND • UI. — • FORT EDWARDS (‘75-’76) £ a — S WATERFORD (‘76-77) — I ST LLWATER (1977) £ SCHUYLERVILLE (‘76 77) 001 I 1 .1 Ii ittl i 1 1 II iii I I 11111 100 500 000 5,000 10,000 50,000 100,000 FLOW (CFS) FiGURE 4-17 COMPARISON OF PCB CONCENTRATION VS FLOW AT VARIOUS MONITORING STATIONS ( OCTOBER,1975-SEPTEMBER, 1977) 1 ±JI JLJB HUDSON RIVER PCB SITE, HUDSON RIVER, L i RA I N 0 A Halliburton Company 4—93 ------- I0.0 : REF: LMS (1979) A 1.0 • £ es. .1* • • • 4,”. .•y.’I’#.. I. •!? • *s 0. 1 1 LEGEND + ROGERS SL4ND (‘77-’79) £ SCHUYLERVILLE (‘77’79) • ST1LLWATER (‘77 ‘79) • W ERF0RD (‘77’79) 0.0I I If itii tI I 1111 11 1 1,000 t O,000 100,000 FLOW (CFS) COMPARISON OF PCB CONCENTRATION FiGURE 4-18 VS FLOw AT VARIOUS MONI1DRING STATIONS ( OCTOBER, 1977-APRIL, 1979) __ HUDSON RIVER PC8 SITE, HUDSON RIVER, NY ____ R4TX N 0 A Haltiburton Company 4-94 ------- 1976 period, the relatively high PCB values could reflect short—term resIdual effects from removal of the dam and subsequent dredging activities. The lower PCB values at Rogers Island, on the other hand, can be explained by the efforts to mitigate the remnant pool deposits prior to data collection. More recent data indicate that the same overall trend in PCB transport rates, from a relatively low value at Rogers island to a generally constant value at Schuylerville, Stiliwater, and Waterford, has continued through 1981. These same data show that Rogers Island PCB loads have remained relatively constant between 1978 and 1981. whereas the loads at each of the downstream points have been significantly decreasing. These data observations, which support the simple no deposition, no scours ’ model, provide an interesting scenario of PCB transport In the Hudson River that is generally consistent with historical activities. From a historical perspective, removal of the Fort Edward Dam and subsequent dredging caused a large quantlty of PCB—contaminated sediment to enter the Thompson Island pool and, to a lesser degree, other downstream pools. With subsequent mitigation measures completed upstream of Rogers Island, the overall transport of PCB across this point was quickly reduced. However, the large slug of sediment deposited in the Thompson Island pool would not have Immediately stabilized, thereby causing an increased concentration and flux of sediments and PCBs across the Thompson Island Dam that continues at a reduced rate today. The material being transported, Including the associated PCBs, appears to remain In suspension with little loss or gain prior to being discharged ever the Federal Dam at Troy. This would explain the measured increase in both suspended sediment and PCB loads between Rogers Island and Lock 4, and the approximate conservation of each parameter between Lock 4 and Waterford. (Recall that no data exist between the Fort Edward Dam and Lock 4 to document where the transition from increasing to conserved sediment load actually occurs.) The progressive decrease in PCB loads with time at the various monitoring points Indicates the gradual return of Thompson island and other pools to their more stable, natural state. The previously documented hot spots near bends In the downstream channel reaches could be remnants of a slug release of PCB—contaminated sediments, due, for example, to dam removal or 4-95 ------- subsequent short—term flood events that scoured the unstable, highly contaminated sediments in the pools above Fort Edward and Thompson island. In summary, available data indicate that deposition and scour of bed sediments within the reaches under study are currently not dominant processes in the overall transport of PCBs to the Hudson River estuary. An exception is the Thompson island pool, which appears to contribute PCB—contamlnated sediments to downstream reaches as a consequence of a historical overload of sediment Inflow to the pool. Recent data trends indicate that stabilization of the Thompson island pool is occurring as sediment Is progressively lost from the pool. Many of the PCB transport—model results appear to be in conflict with field observations and the analysis thereof. These will be itemized In the next section. 4.3.4 Summary and Conclusions The PCB transport model for the Upper Hudson River is composed of three distinct submodels — a river hydraulics submodei, a sediment transport submodei, and a PCB inventory submodel. The HEC—6 hydraulics submodel selected for use is considered to be suitable for Hudson River conditions, but deficiences in model calibration are judged to exist However, because errors in the overall PCB transport model appear to be more sensitive to shortcomings in the sediment transport submodel, any adjustments to the hydraulics submodel would not have significantly altered the final results and conclusions. The sediment transport component of the HEC—6 model is problematical as applied to the current study because organic, and fine— grained materials that play a dominant role In PCB transport are not adequately treated in the model. This deficiency was recognized during the modeltng study but was not believed by the modelers to Introduce significant errors Into the overall study results. This conclusion is now being disputed, and in general the sediment transport submodel is thought to have introduced serious errors into the overall PCB transport predictions. The PCB inventory submodel is a simple PCB mass conservation accounting procedure that, in itself, is adequate for the current level of study. However, the reliability of the results of the submodel is highly dependent on the input data and the results of the sediment transport submodel that have been shown to be deficient. 4—96 ------- The various shortcomings of the three submodels collectively yield results that are inconsistent with field data. The following discrepancies highlight the unsatisfactory performance of the overall PCB transport model and the implications thereof with respect to the study conclusions and recommendations. 1. Model Result : The low flow contribution is a relatively small portion of the overall PCB transport. Data From This Study : The model seriously overestimated high flow contributions. Approximately 50 percent of the PCB load is contributed by low and intermediate flows. Implications : The recommended alternative of reservoir development to reduce flood flows may have less effect on overall PCB transport than was originally estimated. Also, the influence of PCB loadings on Hudson River fish would be more significant since it Is the consistent, low—flow concentrations rather than short—term, storm—related loadings that are more impoitant in this regard. 2. Model Result : Roughly 60 percent of the load over the Federal Dam at Troy originates upstream of the Thompson Island Dam. Data From This Study : Most of the PCB load at Troy originates upstream of the Thompson Island Dam, with a significant portion originating within the pool downstream from Rogers Island. Implications : Dredging of the hot spots within the Thompson Island pool could .acce lerate a stabilization and reduction of PCB loads to the Lower Hudson River estuary. 3. Model Result : Ten percent of the PCB load passing the Thompson Island Dam results from scour within the pool. 4—97 ------- Data From This Study : The PCB transport model overestimated the PCB flux across the upstream boundary (Lock 7) and predicted a net deposition of sediments within the Thompson island pool except during high flows. This Is inconsistent with available data, and leads to an underestimation of the relative PCB contribution from the Thompson island pool. Implication : Based on the 10 percent PCB contribution from the Thompson Island pool, the modeling study concluded that hot—spot dredging within this highly contaminated pool would be more costly but no more effective in reducing PCB loads at Troy than dredging in other pools. The relative contribution of PCBs from the Thompson Island pool is now judged to be more significant than the model results indicate. 4. Model Result : Over the 20—year projection period, 80,000 pounds of PCBs will pass over the Thompson Island Dam and 130,000 pounds of PCBs will pass over the Troy Dam. A related Issue is that dredging the scourable deposits In the lower reaches that contribute to the 50,000—pound increase would effectively reduce PCB loads. Data From This Study : The PCB load is relatively conserved once It passes the Thompson Island Dam.’ That is, there appears to be little net loss or gain of the PCB load between the Thompson Island Dam and Troy Dam. implication : This reinforces the notion that dredging within the Thompson Island pool would be more effective than dredging within downstream pools. 5. Model Result : Total cIeanup of PCB—contamlnated sediment sources upstream from Lock 7 could reduce the PCB load at Tray by 54 percent. Data From This Study : Recent data Indicate very little PCB contributions from above Lock 7 for low and intermediate flow conditions. Data for 4—98 ------- high flow conditions which erroneously dominated the model results exhibit consideréble scatter but also appear to contribute less PCBs than previously predicted. Implication : The removal .of remnant deposits 3 and 5 above Lock 7 may not provide PCB load reductions to the extent projected by the model. 4—99 ------- 5.0 PUBUC HEALTH CONCERNS In examining the public health concerns for the Hudson River PCBs Site, two points must be taken into consideration. First, although a large amount of information was gathered in 1977 and 1978 regarding PCBs in the Hudson River, very little of that information dealt with PCB concentrations at the receptors. Furthermore, the information which was developed then may not reflect current conditions. Limited recent information which is available relative to the Waterford water supply does indicate that the risks associated with the site are low. While difficult to precisely delineate, some risk continues to exist at the current time. Second, all the alternatIves under consideration, including dreciging, contain some element of risk since no alternative can remove all of the PCBs in the Hudson River. Some alternatives may result in a short—term increase In public health risk during implementation. The remedial alternatives evaluation must consider the relative ability of each alternative to reduce the overall, long—term and short—term risks. 5.1 Discussion of PCBs PCBs have been found in the water of the Hudson River, in the air above and near the Hudson, In contaminated sediments, and in remnant deposit areas. Concentrations detected in hot spots and wetlands are shown in Table 5—1. Potential public exposure to these PCBs can occur via the following routes: o Ingestion of drinking water from the Hudson River. • Ingestion of fish and other aquatic life contaminated with PCBs. • Dermal and possible oral exposure during use of the Hudson River for recreational purposes such as swimming. • Inhalation of PCBs adsorbed onto particulate matter. 5—1 ------- Hot Spot 1_7(l) 8( 1) 9_12(1) 13(1) 14(1) 15_17(1) g(1) 19 20 ( 1) 21 ,24 25 26,27 28 29—34 35 36 37 38 39 40 Note (1): Source: TABLE 5-1 HUDSON RIVER PCBs SITE PCB CONCENTRATIONS HOT SPOTS AND WETLANDS Mean PCB Concentration uq/q (ppm) Contaminated Volume m 3 (yd 3 ) 39—81 98,150 (128,350) 99 82,850 (108,350) 28—78 23,400 (30,600) 89 1,550 (2,050) 279 55,150 (72,150) 103—380 46,200 (60,450) 94 11,450 (14,950) 83-249 5,950 (7,750) 75—143 10,650 (13,950) 100 10,650 (13,900) 47—53 7,050 (9,200) 109 36,350 (47,440) 51—516 49,450 (67,700) 105 8,700 (11,350) 51 42,750 (55,900) 116 43,900 (57,400) 501 11,300 (14,750) 161 10,050 (13,150) 62 26,300 (34.400) These hot spots are in the Thompson Malcolm Pirnie, 1980d. Island pool. 5—2 ------- • Ingestion of terrestrial wildlife feeding on vegetation from contaminated marshlands. In addition to the existing concentrations of PCBs, sediment dredging may cause desorption of PCBs from their adsorption sites, with solubilization of certain PCBs Into river water. In the ensuing discussion of public health concerns, the following factors were considered: • Concentration of PCBs found at a site (river, sediment, etc.) • Types of PCBs present • Exposure routes • Water flow conditions, rates, and patterns • Nature and stability of sediments and remnant deposits • Nature of surrounding soil • Location of persons “at risk” PCBs are usually present as a mixture of various chlorinated biphenyls, which differ In number and sites of attachment of chlorine atoms. Tests on animals indicate that oral exposure to PCBs at a 1300 ppm level may result in changes In liver pathology and/or function and In changes in female reproductive capacity. Exposure of the skin to PCBs may result in chloracne and possible tumor formation. Absorption of PCBs can occur via respiratory, dermal, or oral routes. By nature, PCBs are lipophilic and this lipid solubillty seems to increase as the number of chlorine atoms bound to the molecule increases. PCBs have been shown to concentrate in fatty tissue of animals and humans and to cross the blood/brain barrier in man. When considering the toxic effect cited above, the contribution of dibenzofurans, a contaminant found In PCBs, thust be considered. Metabolism of PCBs seems to occur predominantly via the liver—mixed function oxidase system of enzymes which results in hydroxylation at one or more positions of the PCB molecule. PCBs may alter the body’s metabolism of other toxic compounds. 5—3 ------- The Draft Environmental Impact Statement (DEIS, May 1981) gave a “worst caseu value of about 1 milligram per day of PCBs if contaminated fish were eaten and background PCB exposure levels were at least 9 pg/day (EIS, 1981). The report concluded that at this level, sensitive individuals could possibly experience deleterious effects, although these eftects were not specified. At this level of exposure, immune system suppression might also occur. Since evidence of tumor formation in mammals by PCBs has been found, there can be no zero effect-level presently calculated. Several toxicology studies elsewhere have found PCBs in milk of pregnant and nursing women, a situation which poses a possible danger to nursing infants. A possible danger may exist to the unborn fetus whose mother has been or is being exposed to PCBs since some transfer of PCBs by maternal blood may occur and since induction of the maternal microsomal oxidase system of enzymes may lead to increased fetal exposure to toxic metabolites. 5.2 Air Pollution it is believed that air pollution consists mainly of PCBs adsorbed on particulate matter which may be subsequently inhaled. Under the current situation, It is estimated that the air transport rate of PCBs is approximately 3000 lbs/yr from sediments and from the water column (DEIS, 1981). Volatilization of PCBs is dependent upon vapor pressure of the various compounds which, In turn, is a function of the temperature. Volatilization is generally very low. Transport of the PCBs is dependent upon wind conditions and presence or absence of particulate matter. Remedial measures such as dredging and excavation can be expected to dislodge PCBs from sediments and remnant deposits and to enhance the amount of PCBs transported. This may yield concentrations (*TWA = Time Weighted Average). Time Weighted Average (TWA) is the time weighted average concentration for up to a 10—hour workday, 40—hour workweek, to which nearly all workers may be repeatedly exposed, day after day, without adverse effect. 5—4 ------- exceeding the National Institute of Occupational Health (NIOSH) TWA 1 value of 1 pg/rn 3 , and the New York State Department of Health (NYSDOH) recommended maximum of 1.0 pg/rn 3 for ambient air at “...occupied residences and other sensitive receptors.... Data cited in the Malcolm Pirnie report indicate onsite values from <1 pg/rn 3 after 1977, to 8—9 pg/rn 3 during excavation at remnant deposit area 3A. In addition, remnant deposits, especially those on the east side of the river, are in fairly close proximity to residential areas. Some of the remnant deposits are also accessible to the public. No sampling has been conducted to determine the levels of PCB concentrations of the residences or at the undisturbed remnant sites. PCBs are readily absorbed through the lungs. The NIOSH recommendation of a maximum value of 1 pg/rn 3 was based on potential liver damage, adverse reproductive effects, and potential carcinogenicity. 5.3 Sediment Contamination Contaminated sediment represents the largest possible source of PCBs In the Hudson River. There is an estimated 281,700 to 347,200 pounds of PCBs in the bed and banks of the Upper Hudson, of which an estimated 34 percent (134,000 Ibs) was located In the Thompson Island pool in 1977. Remnant deposits are estimated to contain between 46,820 and 108,600 pounds of PCBs. A certain amount of PCBs are removed from the sediments by the processes of desorption or erosion, and enter the water. The rate at which this occurs is dependent upon water flow conditions. Erosion is thought to be the primary mechanism of PCB transport in the Upper Hudson River during high water flows. Desorption predominates at low flows. The process is also dependent upon the nature and stability of the sediments. Organic—rich sediment tends to adsorb PCBs more strongly than less organic—rich sediments. High surface area—to—volume ratio sediment particles will also trap PCBs more effectively than lower surface area— to—volume ratio particles because of an increased number of adsorption sites. 5—5 ------- Some analyses cited by the Malcolm Pirnie report showed concentrations of 5—20 ppm PCB in the river center and along eroding banks, and 50—100 ppm in fine— grained sediment along the depositional shore. The average core or surface concentration of the 20 cited “hot spots” in the Thompson Island pool was 142 ppm. The potential risk to the public from exposure to these PCBs lies in: • Continuous desorption and erosion, causing PCB solubilization and presence of PCBs in water supplies that use intakes on the Hudson River. • Storm events and high flow conditions that would cause resuspension and downstream movement of PCB—laden sediments. • Consumption of PCBs by bottom—feeding organisms with entrance of PCB5 Into food chain. Contaminated sediments may make PCBs available for uptake by the aquatic life. These sediments may be, at least in part, responsible for the levels of PCBs (1980) exceeding the FDA temporary tolerance level of 5 ppm in many fish. (Note: The FDA has proposed reducing the PCB human consumption limits for fish and shellfish from 5 ppm to 2 ppm.) Fishing has been banned in most of the Upper Hudson River, although illegal fishing does occur. The total daily intake of PCBs (Ingestion) may be expected to be about 1 mg if contaminated fish are eaten on a regular basis (Draft EIS, 1981). 5.4 Groundwater Contamination Groundwater contamination occurs from dredge spoil sites and upland municipal landfills in the Upper Hudson basin area. Transport of PCBs from dredge spoil sites via groundwater to the Hudson River is calculated to be 17 pounds per year. Those sites contributing are Lock 1 and 2 sites, Buoy sites 212 and 518, Moreau sites, and special dredge area 13. Loss of PCBs from the areas via erosion was calculated at 20 pounds per year. 5—6 ------- Various wells used for domestic supplies are located in the area of the proposed sediment containment site. These wells range in depth from 25 to 190 feet (8 to 58 meters) (Draft EIS, 1981) and produce up to 76 liters per minute (20 gallons per minute) of potable water. However, the clays in the area of the site are described as uslowly permeable,° and thin lenses of fine sand are present wherein the groundwater is supposed to be essentially immobilized. There is no data showing PCB concentrations In well water in the area. The danger of conta.minatlon of these wells from containment site groundwater does not seem to be great, but more data is needed to substantiate this fact. 5.5 Surface Water Contamination Surface water contamination of the Hudson River, with PCBs emanating from contaminated sediments and remnant deposits, may pose a concern. Hudson River water is used by a number of communities as a source of drinking water. This includes the Village of Waterford, Port Ewen Water District, Village of Rhinebeck, City of Poughkeepsie, and the Highland Water District. In addition, numerous private individuals obtain water from wells near the river. Since the Hudson River serves as the source for the drinking supply of various communities, human consumption of PCBs is possible. The New York State Department of Health guidelines for maximum PCB concentration in drinking water is 1.0 ppb based on health considerations. Using an average daily water consumption for a person of 2 liters per day, then this translates into a maximum possible 2.0 }.tg per day oral intake of PCBs from drinking waters. The oral intake via water must then be added to PCBs inhaled or ingested via fish and aquatic life, and any other background PCB levels. The drinking water supply of Waterford has been periodically sampled by the NYSDOH and by the U.S.G.S. In addition, O’Brien and Gere, a consulting firm, was retained by the State to evaluate the treatability of Hudson River water and in the course, of the report presented PCB concentrations for raw and untreated water. 5—7 ------- NYSDOH results and the O’Brien and Gere (1981) data list are presented in Tables 5—2 and 5—3. It should be noted that in a very recent report dated January 18, 1984 the NYSDOH reported different levels of PCB for approximately the same time interval. Those values are presented in Table 5—4. The U.S.G.S. did not tabulate their data but an inspection of Figure 4 in Schrocler and Barnes (1983) reveals that treated water in their samples usually contained less than 0.1 pg/I of PCB and that out of 46 samples only one contained PCB in excess of 0.3 pg/I (0.62 pg/I). U.S.G.S. data also shows that raw river water did not usually go above 0.7 pg/I in PCB concentration. The concentrations did not approach or exceed 1 pg/I except in a few samples taken at unusually high flow conditions. A level of 0.16 pg/I has been calculated by NYSDOH to represent a lifetime cancer risk ofone in one millIon (10—6). The maximum acceptable exposure level promulgated by NYSDOH is 1.0 pg/I, although the department does not list what health effects it Is designed to protect against. A stricter recommended limit and risk level may be derived from the EPA Ambient Water Quality Criteria for PCB (45 Federal Register No. 231). The derivation is as follows: The concentration of PCBs in ambient water and aquatic organisms which may result in one additional cancer—related death per every 100,000 individuals (105) i 0.79 ng/I. This value assumes that 99 percent of the PCB Intake is from the consumption of fish and also assumes a bioconcentration factor (BCF) of 31,200 in the fish. The BCF is the number of times an organism is capable of bioconcentrating a chemical over the ambient concentration of the chemical In the environmental pathway in which the organisms were exposed. Therefore, at this level of health risk the unit PCB concentration of fish is: (0.79 ng/I) (31,200) = 24.648 pg/I or 24.648 pg/kg, assuming 1 liter of water has a mass equivalent to 1 kilogram. 5—8 ------- TABLE 5-2 PCB LEVELS IN THE ViLLAGE OF WATERFORD DRINKING WATER High Low Average Samples Sampling Value Value Value Organic Chemical Analyzed Period up/I up/I ug/I Arochlor 1221 3 9/29/77 <0.05 <0.05 0 6/1/83 Arochlor 1016/1242 3 9/29/77 0.3 <0.05 0.10 6/1/83 Arochlor 1254 3 9/29/77 0.5 <0.05 0.16 6/1/83 Arochlor 1260 2 10/22/81 <0.05 <0.05 0 6/1/83 Arochlor 1248 1 6/1/83 <0.05 <0.05 0 PCB Total 23 11/15/76 0.01 0 0.02 9/27/77 No value was above the 1 ug/l guideline for PCBs, set by NYSDOH. Source: NY State Department of Health, September 1983. Letter to S. Pedersen, NUS Corporation, Pittsburgh, Pennsylvania. 5—9 ------- TABLE 5-3 Date 7/19/78 8/2/78 8/29/78 9/28/78 10/13/78 10/25/78 11/2/78 12/6/78 1/15/7 2/16/79 Date 8/29/78 9/13/78 10/3/78 10/12/78 11/15/78 12/8/78 1/4/78 2/16/79 5/11/79 5/17/79 5/24/79 5/31/79 6/7/79 6/12,79 6/21/79 6/28/79 7/5/79 7/17/79 8/2/79 8/15/79 8/30/79 10/10/79 10/22/79 PCB CONCENTRATiON OF UNTREATED AND FINISHED DRINKING WATER Poughkeepsie, New York 0.10 0.07 <0.01 <0.01 0.30 0.10 0.14 <0.01 0.06 0.07 Waterford. New York 0.20 0.70 0.30 0.40 0.02 0.02 0.06 0.20 0.05 0.03 0.03 0.10 0.01 0.11 0.01 0.14 o .08 <0.01 0.07 o .06 0.08 0.03 0.01 <0.01 <0.01 0.02 <0.01 <0.01 <0.01 0.10 Untreated (ua/fl Finished (ugh) Untraated (ua/ll Finished (u /l) Source: OBrien and Gere, April 1981. prepared for NYSDEC. Albany, NY Hudson River Water Treatability Study, 5—10 ------- TABLE 5-4 PCB LEVELS IN WATERFORD DRINKING WATER Not Detected Polychiorinated No. of In # High Low Mean biphenyls Samples Dates Samples iq/l ugh _ j Aroclor 1016/1242 11 9/77—6/83 4 0.3 < 0.5 0.07 Aroclor 1254 11 9/77—6/83 4 0.5 <0.05 0.06 PCB (total) 51 6/74—10/81 36 0.6 0. 0.06 Source: NYSDOH. January 1984. Cancer Incidence in Waterford, New York. Final Report. 5—11 ------- When fish or seafood is consumed at a rate of 6.5 g/day, the daily PCB dosage at this level of risk is: (24.648 g/kg)(0.065 kg/day) = 1.6 pg/day This is the daily dose at the 10 cancer risk level regardless of the route of exposure. The PCB concentration of water associated with this level of risk is computed by assuming the consumption of 2 liters of water per day: 1.602 J!Q/dav 0.80 zg/l 2 liters/day The 0.80 . g/I concentration is the recommended limit for the cancer risk level for consumption of PCB contaminated water only. This mâans that on the average, one additional person out of 100,000 people may get cancer if the population drinks 2 liters of water per day with 0.80 g/l of PCB in it. PCB concentrations in Waterford water are generally much lower than this. Given that the average rate of cancer is one person Out of 10, the incremental risks due to PCB in the water seem to be undetectably small. This is also the conclusion of recent U.S.G.S. reports and NYSDOH reports. It should be reali2ed that this limit does not account for other pollutants in the water or for consumption of PCB in other sources. For this reason an in—depth health Impact study and treatability study for Waterford Is recommended. Waterford should represent the worst—case health risk since it is the community closest to the highly contaminated areas. The health risk here appears to be low and it should be even lower in other communities. 5.6 General Risk Assessment There are high PCB concentrations present in the 40 PCB hot spots and in the remnant deposits. Recorde d levels reach 500 ppm ( . g/g) in hot spots (see Table 5—1). PCB movement can occur in the Hudson River via desorption or erosion and consequent solubilization. Conditions of high river flow and scour may 5—12 ------- cause resuspension of PCB—Iaden sediments and movement downstream. increased release of PCBs from remnant deposits due to erosion may also occur under these conditions. Floods and high flow conditions may rework the sediments, disturb hot spots, and expose more highly contaminated sediments to the water interface, making them available to bottom—feeding organisms. The risk to those exposed to PCBs in drinking water alone Is low. The PCB concentration of drinking water has never exceeded either the State—set standard or the EPA—recommended levels for PCB exposure. It appears that incremental risks due to PCBs in drinking water alone are undetectably small. Contaminated fish represent the most serious human health hazard. Many fish levels undoubtedly continue to exceed the FDA—imposed tolerance limit of 5 ppm. The current ban on fishing, in addition to State advisories, is presently designed to eliminate hazards which would be caused by eating fish. Communities situated near concentrated sources of PCB such as dumps and remnant deposits could be exposed to deleterious concentrations of PCB in the atmosphere. Such locations should be monitored. Air contamination is nearly negligible near river sources such as riffles and dams and probably does not represent a problem. Groundwater contamination has not been shown to be serious, but insufficient data are available. In summary, PCBs are present in sediments, remnant deposits, and fish. They are also found, to a very limited extent, dissolved In the river. Given the properties of biomagnification, bioaccumulation, chemical persistence, and stability of PCBs, chronic exposure is of concern. Remnant deposits could pose- a hazard to people crossing over them through direct contact with the contamination. Further data is needed, including, as a minimum, air monitoring at potential receptors, and monitoring of water samples from private drinking wells and from public water supplies, and biotic assays. Remedial actions should be designed to deal with these concerns. 5—13 ------- 6.0 HEALTh AND SAFETY PROCEDURES 6.1 Personal Health and Safety Protection 6.1.1 Remedial Investigation Personnel in the Remedial Investigation stage will be Involved in the sampling of sediments, air and water. Level of protection is based upon the following: • PCBs are lipid soluble and can be absorbed through the skin. Lipid solubility increases as the degree of chlorination increases. • Some PCBs may be carcinogenic in humans. • Other toxic chemical compounds such as dibenzofurans may be found associated with PCBs. • Workers sampling water can be expected to come into contact with water containing about 0.3 pg of PCBs/l (the average concentration found in the river). • Workers doing air sampling near residences may encounter air concentrations of 0.05 — 0.32 pg PCBs/m 3 . Workers sampling sediment are recommended to have PCB—resistant, hooded, Saranex—coated Tyvek Suits with butyl rubber aprons (ankle length with sleeves); inner surgical gloves with outer butyl rubber or neoprene gauntlets; and neoprene boots with disposable outer boot covers. Contact with PCBs and PCB—containing material is likely as the samplers are pulled from the water and contaminated water and sediment drip out. Workers sampling water are advised to have Saranex—coated, hooded, Tyvek suits with butyl rubber aprons (ankle length with sleeves); Inner surgical gloves with outer butyl rubber or neoprene gauntiets; and neoprene boots with disposable outer 6—1 ------- boot covers. Contact with PCBs may occur as integrated depth sampling bottles are pulled from the water and contaminated water drips out. Workers sampling air near residences would not be required to have special protective clothing, because of the low levels expected to be encountered. Decontamination procedures should be implemented for personnel who are sampling sediment and/or water. These personnel should refrain from eating, drinking, or smoking until after they have undergone decontamination, showered, changed clothes, and left the areas of suspected contamination. In addition, people conducting air sampling should also shower and change clothes as soon as possible. They should refrain from eating, drinking, or smoking until they have done so, and have gone off site. 61.2 Remedial Action Personnel in this stage may be involved in the following activities: • Removal of contaminated sediments. • In—place covering of sediments. • Detoxification or destruction of contaminated sediments. • Fencing of remnant areas to restrict access. • Landfilling of contaminated sediments. Decision as to the level of protection necessary is based upon the following: • PCBs are lipid soluble and can be absorbed through the skin. Lipid solubility increases as the degree of chlorination increases. • Some PCBs may be carcinogenic in humans. • Other toxic chemical compounds such as dlbenzofurans may be found associated with PCBs. 6—2 ------- • The majority of PCBs in the air are adsorbed onto particulate matter. • The New York State Department of Health maximum acceptable exposure level is 1 pg/rn 3 for ambient air at “... occupied residences and other sensitive receptors ..., (24 hour average applicable to Hudson River reclamation project only). • The NIOSH recommended permissible exposure limit for PCBs is 1 pg/rn 3 in air averaged over a work shift of up to 10 hours per day, 40 hours per week, with chlorodiphenyls containing 42% chlorIne and 54% chlorine being regulated as occupational carcinogens. These guidelines are for workplace situations. • Workers may come into contact with air concentrations of PCBs exceeding 1 pg/rn 3 . Personnel working at the remnant areas are recommended to have PCB—resistant, Saran x—coated, hooded Tyvek suits with butyl rubber aprons (ankle length with sleeves); inner surgical gloves with outer butyl rubber or neoprene gauntlets; and neoprene boots with disposable outer boot covers. Respiratory protection should consist of a full—face cartridge respirator for particulates. Hard hats should be worn over Tyvek hoods. Contact with PCBs and PCB—containing materials can occur as PCB—laden dirt is stirred up during the clearing and cutting and as winds stir up PCB—contaminated dirt. Workers involved in the placement of fill at the remnant areas are recommended to have PCB—resistant, Saranex—coated Tyvek suits; neoprene or butyl rubber gloves; and disposable outer boot covers over w’rk boots. Respiratory protection consists of a full—face, cartridge respirator for particulates which should be put on if wind blows PCB contaminated soil, or if sampling indicates measurable PCB levels in air. Hard hats should also be worn. Exposure to PCB containing materials can occur if winds stir up PCB—contaminated soil and the dumping process stirs up PCB—contaminated soil. 6—3 ------- Bulldozer operators at the remnant areas are recommended to have PCB—resistant, Saranex—coated Tyvek suits; rubber or neoprene gloves; and disposable outer boot covers over work boots. Respiratory protection consists of a full face, cartridge respirator for particulates which should be put on if wind blows PCB—contaminated soil or If sampling indicates measurable PCB levels in air. Hard hats should also be worn. Exposure to PCB—contaminated material can occur during operations if the bulldozer stirs up PCB contaminated soil or winds may stir up PCB contaminated soil. In addition, the bulldozer operator may have to exit the cab onto the remnant area in event of mechanical failure, thus allowing for further exposure to PCB— contaminated soil. Workers involved 1n fencing off remnant areas are recommended to have PCB— resistant, Saranex—coated, hooded Tyvek suits with butyl rubber aprons (ankle length with sleeves); inner surgical gloves with outer butyl rubber or neoprene gauntlets; and neoprene boots with disposable outer boot covers. Respiratory protection should consist of full—face cartridge respirators for particulates. Hard hats should be worn over Tyvek hoods. Decontamination of major equipment will be performed according to the procedure outlined in the NUS Quality Control Procedures Manual (NUSQCP 11—11). Personnel decontamination will be performed according to the NUS Health and Safety Manual. These procedures may be modified, depending on site conditions. Decontamination procedures must be implemented for all personnel mentioned In Section 6.1.2. Personnel should refrain from eating, drinking, or smoking until after having undergone decontamination, showered, changed clothes, and left work areas. 61 Health and Safety Monitoring Periodic monitoring of air, water, and sediment samples for PCBs is needed to ensure protection of personnel. Use of a respirable dust monitor may also be 6-4 ------- warranted. All workers expected to come into contact with PCBs or PCB— contaminated material should have a blood PCB analysis performed prior to working on site and following completion of their task. 6—5 ------- 7.0 REVIEW OF NEW TECHNOLOGY In the past few years there has been a strong interest in the development of PCB treatment technologies. The impetus of this search for new disposal methods is the need to eliminate the vast quantities of PCBs presently in storage throughout the United States. Incineration at high temperatures (2,000°F and above) has been the only procedure recommended by the EPA to date. One problem that this presents is that there are only two EPA—approved incinerators, one in Texas and the other in Arkansas. These incinerators are non—mobile and would require substantial transportation costs for the shipment of Hudson River sediments. This establishes the need for portable, more cost—effective PCB destruction methods. This review of new technologies will include chemical treatment methods, advanced thermal (non—incineration) techniques, and biological treatment methods. For this purpose, a literature search was conducted to locate advances in PCB treatment (Detoxification, Degradation, Destruction) and analysis technologies since 1980, which is the year in which the NYSDEC prepared its EIS. The criteria for the evaluation of these technologies were based upon the state of development and the effectiveness of a process for treatment of Hudson River sediments. Three categories of treatment processes were studied as listed below: • Biological systems • Dechlorination processes • Destruction processes. Microbial degradation or biodegradation of PCBs in river sediments is dependent on the degree of chlorination and the position of the chlorine atom on the biphenyl molecule. At least 20 different bacteria are believed to be capable of breaking down PCBs into water and carbon dioxide, in a period of 90 to 130 days (Chemical Engineering, 1983). This process has shown only limited success during laboratory work for wastewater treatment processes. The dechlorination process involves the removal of the chlorine atoms from the biphenyl molecule. The process mechanism includes bringing the PCBs in contact 7—1 ------- with a sodium or potassium compound that will band to the chlorine. The end products of this method are reportedly hydrocarbons and a salt. The processes looked at in this study are listed below: Processes found to be applicable for the dechlorination of PCBs in contaminated sediments • Acurex • Hydrothermal • KOHPEG • NaPEG • PCBX • Goodyear Processes with which dechlorination treatments could not be used with contaminated sediments • LARC — Light Activated Reduction of Chemicals • Photodecomposition PCB destruction mechanisms are all essentially the same, with one exception: wet oxidation (Wet Air Oxidation). The destruction process involves the thermal annihilation or chemical oxidation of PCBs. Only one of these processes, rotary kiln incineration, has been demonstrated on a full scale and is permitted by the EPA. The, following is a listing of those destruction processes which were considered. Processes found to be applicable for destruction of PCBs in sediments • Plasma Arc • Pyromagnetics Incinerator • Rotary Kiln • Thagard HTFW (High Temperature Fluid Walt) Reactor • Wet Air Oxidation 7—2 ------- Destruction processes inapplicable for use with contaminated sediments : • Molten Salt Incinerator • Controlled Air Incineration • Fluidized Bed Incineration • Ozonation • Ultraviolet/Ozone 7.1 Treatment Processes The following subsection includes descriptions of PCB treatment technologies. A short description of the process is given, along with a discussion of the applicability of the process to contaminated sediments. 7.1.1 Acurex The Acurex system is a dechlorination process using a sodium reagent in a nitrogen atmosphere to decompose PCBs. A portable batch unit using the sodium—based reactant is used to change PCBs in transformer oil to NaCl and polyphenyl (Miille, 1982). PCB—contaminated sediments must first be solvent washed to extract the PCBs before entering the reactor. The solvent is later reclaimed for reuse. This process should prove applicable for use with contaminated sediments although it has been tried only at the laboratory level. Large—scale use should follow, pending approval of current testing (Baker 1983). 7.1.2 Biological Systems Biological degradation of various PCB species has met with only limited success (National Research CouncIl, 1979). Highly chlorinated biphenyls (6 chlorines) undergo negligible degradation due to biological processes, while the lesser chlorinated compounds (1—5 chlorines) decompose much more readily. This inconsistency is explained by the fact that no specific microorganism has been discovered that will selectively oxidize or degrade the higher chlorinated compounds (Baker, 1983). 7-3 ------- 7.13 Controlled Air Incinerator The Los Alamos National Laboratory has modified a controlled—air, radioactive waste incinerator to burn PCB waste. The incinerator is a conventional dual— chamber, controlled—air design with operating temperatures for PCB destruction ranging from 1,600°F (Chamber No. 1) to 2,000°F (Chamber No. 2). Attempts are currently under way to obtain a permit for a PCB test burn (Fradkin, 1982); however, the state of development renders this process unsuitable for use on contaminated sediments. 7.1.4 Fluidized Bed Incinerator PCB destruction is obtained with this method at a temperature of 1250°F using a chromic oxide and aluminum catalyst. Rockwell International’s (the developer) fluidized bed incinerator recently underwent a successful one—gallon test burn of PCBs (at 700°F) for the EPA (Fradkin, 1982). Although this process has been proven useful for PCB destruction, there are no plans to develop this system any further, or to use it in connection with contaminated sediments. 7.1.5 Goodyear The Goodyear system includes a non—mobile, exothermic process using sodium naphthalide in an inert atmosphere for the destruction of PCBs in oil. Operating at ambient temperatures, the system destroys PCBs in 5 minutes, producing sodium chloride and nonhalogenated polyphenyls as by—products (Berry, 1981). Treatment of sediments would first require solvent extraction so that the PCBs would be in a liquid medium. 7.1.6 Hydrothermal The Japanese—developed Hydrothermal PCB decomposition process has, in the laboratory, replaced the chlorine atoms of PCBs with hydroxyl groups in the presence of methanol and sodium hydroxide. Operating at a temperature of 570°F and a pressure of 2,560 pounds per square inch, this process is reportedly safe, 7-4 ------- simple, and rapid. Since much testing and development need to be done, this process will most likely not be available for use with this project In the near future. 7.1.7 KOHPEG The KOHPEG process uses polyethylene glycols and potassium hydroxide to destroy PCBs in nonpolar liquids. This process is reportedly more reactive and tolerant of impurities than the similar process, NaPEG (Brunelle, 1983). The reaction conditions are mild, with complete PCB degeneration in 2 hours at temperatures of 170°F to 250°F. This technology is apparently applicable to contaminated sediments, although testing has not yet been completed (Baker, 1983). 7.1.8 LARC The Light Activated Reduction of Chemicals (LARC) process, developed by the Atlantic Research Corporation, uses ultraviolet light (UV) and hydrogen gas to effect. dehalogenation (Fradkin, 1982). This process involves a stepwise dechlorination of the biphenyl, with the formulation of a lesser chlorinated and eventually dechlorinated compound (Valentine, 1982). Its use on river sediments is restricted by IJV light—absorbent materials present in the water, and the requirement of a constant hydrogen source. The process Is patented but has not been proven useful on contaminated sediments (Baker, 1983). 7.1.9 Molten Salt Incinerator The molten salt incineration, process, demonstrated by Rockwell International, destroys PCB waste by injecting a mixture of the waste and air into a sodium carbonate/molten salt mixture at 1450°F to 1800°F (Johnson, 1982). By mid—1983, a portable incinerator rated at 225 pounds per hour should be available. Very good results have been achieved for PCB removal using this method, but this system has not been recommended by Rockwell for use with organic river sediments (a high ash material) due to the high flow requirements needed for transport through the sodium carbonate solution (Baker, 1983). 7-5 ------- 7.1.10 NaPEG The NaPEG (trademark) system, developed by the Franklin Research institute, uses molten sodium metal dispersed in a polyethylene glycol solution to treat PCB— contaminated oils. This process, which is insensitive to moisture or air, was successful in laboratory bench—scale testing of PCB breakdown in soils. The reaction products are oxygenated organics, sodium chloride, and polyglycol or glycols that do not bioaccumulate and will biodegrade (Fradkin, 1982). Although the EPA is optimistic about the use of NaPEG with contaminated sediments, testing results will not be available for some time (Baker, 1983). 7.1.11 Ozonation The ozonation of PCB—contaminated waste is a Canadian process in which ozone is used to destroy PCBs in liquids (oils and water). Laboratory work shows that 95 percent of PCBs in wastewater is destroyed by this process. This process is currently in the developmental stage, and has not been applied to contaminated sediments. Accordingly, it is not kr own if it will be available for use with the Hudson River project (Berry, 1981). 7.1.12 PCBX The PCBX system is a mobile system used for the destruction of PCBs found primarily in transformer oils. This system was developed by Sun Ohio, and was the first chemical PCB—treatment—method approved by the EPA. The system reportedly uses sodium salts of organic compounds in an amine solution to eftect PCB destruction (Fradkin, 1982). The use of this system for contaminated sediments is possible, although more tests must be conducted before a recommendation can be made (Baker, 1983). Solvent extraction of the PCBs from the sediment would be required. 7—6 ------- 7.1.13 Photodecomposition Photodecomposition of PCBs in liquids occurs when PCBs are Irradiated by light in the presence of an amine. Tests on contaminated soils showed that no significant reduction of PCBs occurred after irradiation of the soils (Battelle, 1982). 7.1.14 Plasma Arc The plasma arc process is a dechlorination technique developed for PCB solids destruction by molecular fracture (Fradkin, 1982). The plasma arc is produced by a low—pressure gas through which an electric current (arc) is passed. The by—products that result from passing PCBs through this arc are simple because the final states are atomic (Cl, H, C atoms) (Barton; Arsenault, 1981). This process Is expected to work on contaminated sediments and has the advantage of not requiring a solvent extraction of the solids. The development of a soil/sediment facllit is still in the future, with the expectations of an energy—efficient process (Baker, 1983). 7.1.15 Pyromagnetics incinerator This Incinerator, developed by the Pyromagnetics Corporation, is a portable unit for the detoxification of approximately one ton per hour of total solids. The destruction process uses 5,000 pounds of molten Iron at 2,600 to 2,700°F in a primary chamber into which 200—300 pounds of sand in addition to the contaminated sediments are added (per hour). The volatiles are removed and burned in a second chamber at 4,000°F, while the nonvolatiles are siagged off with the molten sediment and sand (Fradkin, 1982). EPA approval has yet to be given to this process since a test with PCBs has not been completed. One problem that may be encountered is the likelihood of the byproducts being greater in volume than the contaminated feedstock (Baker, 1983). 7.1.16 Rotary Kiln The rotary kiln is a high—temperature PCB destruction technique currently available to the market. Two facilities have EPA permits (Texas and Arkansas) to 7—7 ------- operate incinerators in the 1800 to 2,200°F temperature range. In addition, a test by the EPA is underway using a mobile rotary kiln that will operate at a temperature of 2,200 °F (Fradkin, 1982). 7.1.17 Thagard HTFW Thagard Research Corporation has developed a high—temperature—fluid wail reactor (HTFW) that completely pyrolyzes PCBs, and fixes the residues into nonleachable glasses (Matovich, 1982). This reactor maintains a high temperature (4,000°F) by radiant heat emanating from a gaseous fluid. envelope (generally nitrogen), operating without catalysts, and thus unaffected by impurities in the feed (water, sulfur, metal). Laboratory tests using hexachlorobenzene (HCB) as a surrogate for PCBs showed a destruction order of 99.9999 percent upon a 0.1 second reaction time (Hornig, 1981). 7.1.18 Ultraviolet/Ozone The technique of using ultraviolet light and ozone to destroy PCBs in wastewater is currently in the pilot plant stage. The process costs are reported to compare favorably with carbon adsorption and incineration (Arismen; Music, 1980). A deterrent to the use of this system on river sediments is that this method cannot handle wastes where the ultraviolet• light cannot penetrate the contaminated material (Edwards, et al., 1981). 7.1.19 Wet—Air Oxidation The wet—air oxidation system uses a co—catalyst and moderate temperatures to achieve 99 plus percent destruction of even highly chlorinated biphenyls (Randall, 1981; Miller, et al., 1980). One method uses a bromide and nitrate anion catalyst in an acidic aqueous solution. Additional information is proprietary although it is reported that this system would be very useful for soil/sediment detoxification (Randall, 1981). 7—8 ------- 72 Analytical Process A new technique has been developed for the analysis of PCBs in soils and sediments. The process, developed by EPA Region I, uses solvent extraction to remove the PCBs from the soil or sediment, and sample analysis is effected by gas chromotography and electron capture detection. Accuracy levels of 0.5 parts per million (ppm) are obtainable In field work using an Analytical Instruments Development Inc. (AID) 511 portable gas chromatograph (Porco, 1983). The extraction process is a three—step process beginning with the addition of water to the soil/sediment sample. A second phase is then added——either methyl or ethyl alcohol——and the sample agitated. After the final phase——hexane——is added and agitated, the hexane phase is separated and then analyzed. The analytical process is accomplished by Injecting the sample into a heated column where component separation takes place. PCBs are then detected by electron capture. The use of the analytical method in the field should be very useful for obtaining quick turnarounds when many samples must be taken or when results are needed In a hurry. 7... 9 ------- 8.0 INVES11GAT1ON OF REMEDIAL ALTERNATiVES 8.1 Review of Previously Developed Alternatives 8.1.1 Alternatives for PCBs in River Sediments 8.1.1.1 No—remedial—action Alternative The following two options are available under the no—remedial—action alternative: • No Remedial Action with Continued Routine Dredging This alternative assumes that no remedial action will be taken, and routine channel maintenance dredging will be continued by New York Department of Transportation. It is estimated that such dredging would remove PCBs at an approximate rate of 5,000 lb/yr (Hetling et al., 1978). The PCB transport model developed by Lawler, Matusky, arid Skelly (1978) has previously been used to estimate the annual average PCB load at Troy Dam and to predict the time period over which significant amounts of contaminated sediment would exist in and continue to be transported from the Upper Hudson River. The model was later used to estimate the change in PCB transport rate brought about by various remedial activities. More recently the model results were adjusted to account for PCB losses due to routine maintenance dredging and atmospheric PCB transfer. The analysis of Section 4.3 indicated a number of shortcomings in the model. One problem was that the model overestimated sediment PCB transport at high flows and underestimated it at low flows. Some recent calculations of PCB transport from USGS monitoring data indicates that the current transport rate may be leveling to about 1,500 lbs/yr (Section 4.0). Table 8—1 compares PCB transport projections using the model results and recent estimates of PCB transport from measured values for various alternatives. The projections In the table account for 8—1 ------- TABLE 8-1 * PCB TRANSPORT PROJECTIONS USING LMS MODEL DATA COMPARED WITH TRANSPORT PROJECTIONS USING CURRENT ESTIMATED TRANSPORT RATE (SECTION 4) No Remedial Action — Discontinued Maintenance Dredging 1 Transport Years to PCB PCB PCB Rate Exhaust PCB Transport Volatilized Dredged ( Ib/yr) Supply Year ( Ibs) ( Ibs) ( Ibs ) LMS Model 7200 40 2018 290,000 60,000 RAMP 1500 117 2095 175.000 175,000 No Remedial Action — Continued Maintenance Dredging 1 LMS Model 7200 31 2009 225,000 78,000 47,000 RAMP 1500 64 2042 96,000 95,000 159,000 Reduced—Scale Dredging Alternative 2 LMS Model 6700 25 2003 170,000 47,000 105,000 RAMP 1500 55 2033 82,500 62,500 205,000 .3 Full—Scale Dredging Alternative LMS Model 5700 21 1999 127,000 20,000 205,000 RAMP 1500 46 2024 69,000 41,300 240,000 Table computations assumed: 350,000 pounds of PCB in storage. Negligible contribution of PCB by remnant deposits. A base year of 1978. 48 percent removal under full—scale alternative and 30 percent removal under reduced—scale alternative. - * Lawler, Matusky and Skelly. Footnotes continued on page 8—3. 8—2 ------- TABLE 8-1 PCB TRANSPORT PROJECTIONS PAGE TWO 1. Assumes dredge removal rate of 2,500 lb/year of PCB. Also assumes air transport rate of 1,500 lb/year of PCB. 2. Assumes 5 years to complete cleanup, during which transport rates, air transport rates, and dredge removal rates are equal to no—action. After clean- up, air transport rates and dredge removal rates are 70 percent of original. 3. Assumes 5 years to complete cleanup, during which transport rates, air transport rates, and dredge removal rates are equal to no—action. After clean— up, air transport rates and dredge removal rates are 62 percent of original. 4. Includes amount of PCBs dredged during remedial action.- 8—3 ------- PCB losses due to maintenance dredging and atmospheric transport. The average annual volatilization rate of 1,500 lb/yr and the average annual dredge removal rate of 2,500 lb/yr adopted in the DEIS are assumed. According to Table 8—1, the number of years it would take to deplete the PCB stored in the Upper Hudson River, with no remedial action and continued maintenance dredging, will vary from 31 to 64 years. During this time, between 96,000 and 225,000 pounds of PCB would be transported to the estuary. Currently, the PCB—removal rate due to dredging in thern New York Harbor is estimated at 4,000 lb/yr (DEIS, 1981). Earlier work (DEIS, 1981) estimated that if this rate is maintained and if 100 percent of the PCB mass at Tray enters New York Harbor, then the average PCB concentration in harbor sediments would increase to approximately 6 ppm by the year 2013. This analysis involved the assumption that the PCB concentration of the sediments being dredged remains the same regardless of the effects of deposition and dredge spoil removal. This is a faulty assumption because dredging generally removes only the most recently deposited sediments, and according to Bopp (1982), the recent material being deposited in the Harbor area has been dramatically decreasing in PCB content. It is in no way certain that all of the PCBrcontaminated material in the Upper Hudson will be removed and transported to the harbor in the time periods specified. It is estimated that dredging in the vicinity of Albany (between milepoints 140 and 150) removes between 1,500 and 1,800 pounds of PCB per year. This removal rate equals the current estimated transport rate at Troy. In any event, It is likely that PCBs will continue to migrate to the harbor in decreasing amounts for a greatly extended period of time. It is expected that, at the worst, the concentration of PCBs in previously—deposited harbor sediments will remain at current levels, and that the level of PCB5 in fresh dredge material will decrease. 8-4 ------- The previously used sediment transport model (Lawler, Matusky, and Skelly, 1978) was used for quantitative evaluation of PCB transport. However, the model does not evaluate the effects of uneven downstream deposition. A knowledge of the distribution of the sediment deposition is critical for the evaluation of potential for deposition near potable water intakes, fish spawning grounds, navigational channels, and docking areas (DEIS, May 1981). • No Remedial Action with Discontinued Routine Dredging This alternative assumes that no remedial actions will be taken, and that routine channel maintenance dredging in the Upper Hudson River will be discontinued to eliminate the need for secure containment sites. According to the projections in Table 8—1, between 175,000 and 290,000 pounds of PCB will be transported to the estuary If routine dredging Is discontinued. Approximately 40 to 117 years would be needed for cleanup of the Upper Hudson to be completed. Most of the difference in the projections of Table 8—1 lies in the fact that over a period of 117 years, twice as much PCBs will be transported Into the air. Earlier work (DEIS, 1981) reported that resultant PCB concentrations In the Albany turning basin would increase, but that concentrations In the New York Harbor sediments would not. However, as was pointed out in the previous section, the current removal rate of PCBs near Albany equals the currently estimated transport rate. Should routine channel maintenance be discontinued, PCB transport will be more significant than the preceeding no—remedial—action alternative. Between 30 and 80 percent more PCBs would be transported into the estuary, and transport would continue to 2018 at the least and possibly extend until 2095 and beyond. It also should be noted if navigational channels were not maintained, that all shipping would eventually cease due to sediment build—up. 8—5 ------- 8.1.1.2 River Sediment Dredging These alternatives assume that various portions of the contaminated sediments will be removed by mechanical or hydraulic dredging. Three different dredging alternatives have been investigated: • Bank—to—bank dredging • Full—scale dredging of 40 hot spots (EPA recommendations vs NYSDEC recommendations) • Reduced—scale dr dging of a portion of the hot spots Bank—to—Bank Dredging Bank—to—bank dredging would require a much greater amount of operating equipment, operating time, and a much larger containment area than would be required for either of the other two less extensive dredging alternatives. The estimated total cost is on the order of $250,000,000 (DEIS, 1981). Full—scale Dredging of 40 Hot Spots The full—scale dredging of the 40 hot spots would be expected to occur over a 2—year period. During the first year of operation, the 20 hot spots in the Thompson Island pool would be dredged using either the hydraulic or clamshell method. All waste materials would be disposed of in the containment site, and the filled portion of the containment area would be covered at the end of the season. During the second year, the remaining hot spots in the lower pools would be dredged using the clamshell method. The waste material would be disposed of in the containment site, and the rest of the containment area covered and sealed (DEIS, 1981). As a result of the full—scale dredging program, it is expected that approximately 48 percent of the total PCBs would be removed from the river. After the cleanup 8—6 ------- action, it would take from 16 to 41 years bra total of between 69,000 and 127,000 pounds of PCB to be transported to the estuary (Table 8—1). Both landfilling and detoxification methods have been considered for the disposal of contaminated sediments. Those methods include: • Detoxification/Destruction — Incineration has been recommended as the most effective and best understood means of destruction of liquid PCBs. Biological degradation has been found to be successful on lower Aroclors. However, no organism has yet been found to degrade PCBs within a reasonable time span. PCBX has been demonstrated on transformer oils but not on contaminated sediments (DEIS, 1981). • Containment — A 250—acre site has been selected by NYSDEC near Fort Edward for use as a secure containment site. Previously conducted field investigations indicated that subsurface conditions at the proposed site were suitable for construction of a secure landfill. Both gravity and mechanical methods of sediment dewatering were considered; gravity dewatering was expected to require from 1 to 2 years for completion, whereas mechanical dewatering would Incur additional costs on the order of $5,000,000 (DEIS, 1981). Following the second season of dredging, the landfill is to receive a clay cap in order to reduce both infiltration and volatilization. A design capacity of 2,260,000 yd 3 was selected for the full—scale dredging of 40 hot spots (DEIS, 1981). Reduced—scale Dredpinq of a Portion of the Hot Spots Because of Federal funding limitations under the Clean Water Act, It was necessary to consider a reduced—scale dredging project. The Thompson Island pool would be selected as the first dredge site since transportation and treatment costs are low compared to other hot areas. The selection of hot spots to be dredged in the lower pools will proceed following an evaluation of results from a proposed probing and sampling program. Due to cost constraints, a clamshell dredge with 8—7 ------- hydraulic pumpout systems may be required for the dredging in the Thompson Island pool (DEIS, 1981). In addition, remnant deposits 3 and 5 would be provided with top covering and fencing, rather than removed and disposed into the containment site (DEIS, 1981). It is expected that the reduced—scale project would allow for the removal of approximately 30 percent of the PCBs from the river. Under the reduced—scale dredging alternative it would take from 20 to 50 years after cleanup for some 82,500 to 170,000 pounds of PCB to be transported to the estuary (Table 8—1). This is between 14,000 and 55,000 fewer pounds of PCB transported to the estuary than would be transported if the no—remedial—action/continued maintenance dredging alternative were to be implemented. Alternately, approximately 32,000 pounds less PCB will be transferred to the atmosphere and from 46,000 to 58,000 pounds more PCB will be dredged under the reduced—scale dredging option. Sediment disposal alternatives are the same as those discussed under the full—scale dredging project. Should a secure containment site be chosen, it is expected that a capacity of about 1,100,000 Vd 3 would be required. 8.1.1.3 Control River Flows In order to reduce PCB migration during high river flows, this alternative suggests controlling the Upper Hudson River flows from the Great Sagandaga Lake at the Conklingville Dam. Flows from the Conklingvllle Dam account for approximately 28 percent of the total flow at Fort Edward during normal flows and approximately 20 percent during the 100—year flood (DEIS, 1981). There are no other flow controls on the Upper Hudson River. PCB concentration data obtained from U.S.G.S. monitoring stations have indicated that PCB concentrations in the Upper Hudson River are flow—dependent. Considering the load of PCBs in the river water column, it appears that flows of 8—8 ------- less than 12,000 cfs between Schuylerville and Stillwater carry very low loads of PCBS, on the order of less than 20 lb/day (DEIS, 1981). Accordingly, It would be necessary to maintain river flows of 12,000 cfs or less in order to avoid substantial transport of PCBs. Since the water flow over the Conklingville Dam constitutes only 20 to 28 percent of the total flow at Fort Edward and since flows greater than 12,000 cfs occur 10 percent of the time between Schuylerville and Stillwater, It is apparent that either a substantial reduction of flow from Great Sagandaga Lake or additional dams would be required. Such a reduction may have a deleterious impact on the generation of hydroelectric power, maintenance of navigable flows, and protection of recreational value of the lake (DEIS, 1981). 8.1.1.4 In—River Detoxification The in—river detoxification alternatives include techniques used to Isolate or destroy the PCBs without removing them from the river. Major alternatives include: • Degradation by ultraviolet ozonation • Chemical treatment • Bioharvesting • Activated carbon adsorption Degradation by Ultraviolet Ozonation The technique of ultraviolet ozonation encompasses two consecutive chemical reactions: (1) use of ultraviolet radiation to decompose ozone which has been previously added to the waste, and (2) formation of highly reactive radicals to oxidize the PCBs. Ilowever, this technique is currently only applicable to eftluent water treatment (Malcolm Pirnie, 1980d). and is therefore not suitable for neutralization of PCBs in contaminated river sediments. 8—9 ------- Chemical Treatment In—river chemical treatment has not been extensively investigated. It is expected that it would be difficult to selectively treat the river sediments without affecting the water column. All of the potential treatment techniques examined for this RAMP have not yet been developed beyond the laboratory stage (Malcolm Pirnie, 1980d). Bi oh a rvesti n p This technique includes the removal of all aquatic organisms from the Hudson River which have accumulated high PCB concentration, and subsequent disposal in an environmentally acceptable manner. It has been estimated that this method may require from 100 to 10,000 years to complete. (DEIS, 1981). Activated Carbon Adsorption Carbon adsorption is presently the most widely used process for the removal of PCBs from industrial wastewater (Malcolm Pirnie, 1980d). To apply the principle to river sediments, it has been proposed that a magnetized granular activated carbon media be applied to the bottom sediments. The media would then be retrieved with a continuous belt—type collection device (DEIS, 1981). It has been estimated that costs for utilization of this alternative would be within the range of $300/acres to $3,000/acres, excluding the cost of storage and destruction of the contaminated carbon (DEIS, 1981). However, the concept has not been fully developed and applied to a river system. 8.1.1.5 In—River Containment of Hot Spots In—river containment of PCB hot spots has been considered for depositional areas that are not located in the main channel. This alternative could reduce the possibility of PCB transport and dispersal from contaminated areas. 8—10 ------- For relatively shallow deposits, In—river containment can be accomplished by a variety of methods including: • Earthen dikes or berms. These structures would be built parallel to the river bank, separating the contaminated sediments from the deeper river channel. A clay cap could additionally be utilized to further isolate the PCBs from the active environment. Wetland vegetation would be planted to stabilize the site (Supplemental Draft Environmental Impact Statement (SDEIS), 1981). • Spur dikes. This method consists of the placement of riprap along the upstream shoreline of the wetland and the construction of a dike at the end of the riprap, angled downstream and outward into the river. Riprap is also placed on the face of the downstream end of the dike for scour protection (SDEIS, 1981). • Bulkheads, which are constructed of pilings and sheetings and are used similarly to dikes or berms (SDEIS, 1981). • Sheet pilings, which are driven into the river bottom parallel to the direction of flow. The pilings then form a relatively impervious boundary by an interlock of the sheet pile edges. • Impermeable liner. Hot spots would be covered with an impermeable material which is resistant to scour. The preceding methods are suitable for hot spots which are located in areas with a history of deposition. Typical areas would include: • Backwater or eddy deposits, commonly formed behind projecting points of stable land (SDEIS. 1981). • Deposits at the mouths of tributaries (SDEIS, 1981). 8—11 ------- • Historically stable deposits on the insides of meander bends (SDEIS, 1981). • Areas of partially restricted flow conditions resulting from the disposal of dredge spoil during routine channel maintenance (SDEIS, 1981). The cost—effectiveness of stabilizing two wetland hot spots (hot spots 8 and 35j was evaluated by the SDEIS (1981). It was determined that earthen diking of these areas would, on the average, be slightly more expensive than dredging and containing the contaminated sediments. In areas that are less than 6 feet below the mean river stage, earthen diking may be slightly less costly than dredging. However, in—place stabilization by earthen dikes would not be effective in reducing scour at river flows higher than the 5 year flood, and the transfer of PCB to the water column and aquatic biota during low flows would not be abated. Another alternative, which is applicable to deep as well as shallow deposits, has been considered for in—river containment of PCB hot spots. The recommended procedure would be to cover the contaminated sediments with a plastic liner, silt and rocks. However, during high flows, the silt may be scoured free and the liner ruptured with a subsequent release of contaminated sediments (SDEIS, 1981). 8.1.2 Alternatives for PCBs in Remnant Deposit Areas 8.1.2.1 No Remedial Action This alternative assumes that no additional remedial actions will be taken at the remnant areas; bank stabilization, seeding, and material removal measures of varying degrees have already been taken between 1975 and 1978. Volatilization, high—river—flow scour, and long—term erosion would be allowed to continue. This action is proposed as a component cit the reduced—scale dredging project (DEIS. 1981). 8—12 ------- 8.1.2.2 Restricted Access Under this alternative, measures would be taken to deter access of people, vehicles, animals, etc., to the remnant deposits. Measures that .would be taken include: • Construction of chain—link fences on the landward sides of the deposits. • Signs, which warn of the presence of toxic wastes, would be placed on all sides of the deposits. • Continued maintenance of fence and signs. • Grass seeding of disturbed and unvegetated areas. • Safety precautions for workers at the sites. Although this alternative would reduce the potential for human contact with PCB— contaminated sediments, it would not prevent losses from high flows and long—term erosion (DEIS, 1981). 8.1.2.3 In—Place Containment of Remnant Deposits To encapsulate the contaminated remnant areas, the following construction procedures would be required: • Placement of an impermeable cover, either man—made or clay or soil. • Construction of a protective blanket, composed of graded material and designed to withstand flood flow velocities. • For complete encapsulation, installation of a curtain wall to deter groundwater infiltration. 8—13 ------- Associated construction costs can be expected to be extensive, as access roads would be required and between 5,000 and 10,000 truck trips would be needed to transport materials to the sites (Malcolm Pirnie, 1980d). This alternative would reduce river contamination from the remnant sites, protect against scouring under flood conditions, and nearly eliminate volatilization. However, the remnant areas would still remain a long—term risk dependent on erosional changes of the river channel. Continual maintenance and monitoring would be required. Also, the construction of a surging dam at Fort Edward would submerge and eventually destabilize the remnant deposits, resulting in further release of PCBs (DEIS, 1981). 8.1.2.4 Removal of Contaminated Materials at Remnant Deposit Areas These alternatives assume that all or a portion of the remnant deposit areas will be removed. Complete Removal of all Remnant Deposit Areas Comp(ete excavation of all of the remnant deposit sites would require the movement of approximately 370,000 cubic yards of contaminated sediments, and between 20,000 and 40,000 truck trips would be required for transportation. About 46,000 pounds of PCBs would be removed from the site, which would account for 14 percent of the total PCB mass believed to be in the Hudson River (DEIS, 1981). The major disadvantage of this concept is the removal of sediments with low levels of contamination, resulting in low cost—effectiveness. • Complete Removal of Deposit Areas 3 and 5 Complete excavation of remnant deposits 3 and 5 would require the movement of approximately 215,500 cubic yards of contaminated sediment and require between 11,000 and 22,000 truck trips to remove the 8-14 ------- matenal. No additional measures would be taken at remnant sites 1, 2 and 4 (Malcolm Pirnie, 1980d). Under this alternative, several advantages become apparent, Including: — Removal of the material (remnant sites 3 and 5) with the highest concentration of PCBs in the Hudson River system. — Substantial reduction of a potential long—term source of contamination. — Substantial reduction of PCB volatilization. — The lower cost of PCB removal compared to the costs associated with removal or containment of PCBs at other contaminated sites in the Hudson River system (DEIS, 1981). • Partial Removal of Deposit Areas 3 and 5 The NYSDEC has considered, as an alternative, removing only a portion of the contaminated sediments from remnant deposits 3 and 5. It was suggested that deposit 5 be excavated to a depth of 8 feet. Also, It was recommended that deposit 3 be excavated to a depth of 1.5 feet and/or to an elevation of 134 feet, and, at the southern end of the deposit, to the depth of the water table. A total of about 73,400 cubic yards of contaminated sediment would be removed from the two remnant deposit sites (DEIS, 1981). Lawler, Matusky, and Skelly (LMS) have also proposed a partial removal plan for remnant deposits 3 and 5 which would excavate all material above an elevation of 134 feet in the remnant areas. Under this proposal. approximately 44,500 cubic yards of contaminated sediments would be removed (DEIS, 1981), and roughly 3,700 to 7,400 truck trips would be required (Malcolm Pirnie, 1980d). 8—15 ------- The LMS proposal was planned to accommodate the potential reconstruction of the Fort Edward Dam. Fluctuations in dam pool elevations would tend to wash PCB5 trom remnant deposits of equal elevation. Correspondingly, excavation to an elevation of 134 feet would remove all contaminated sediments in the area of pool fluctuation which would be between 136 and 142 feet (Malcolm Pirnie, 1980d). Partial removal of remnant deposit 3 is an advantageous alternative since a large mass of PCBs could be removed by excavation of a relatively small amount (13 percent) of the remnant deposit. Hauling costs would be substantially reduced from the complete removal alternative. AddItionally, it would be possible to seal the -remaining PCBs and contaminated sediment in place. 8.2 Review of New Alternatives An evaluation of the treatment technologies discussed In Section 7.0 indicated that although all of the technologies proved to be useful——or potentially so——for removing PCBs from oils, not all of the treatment methods could be used in connection with PCB—contaminated sediments. Twelve of the treatment technologies were found to be applicable to sediment decontamination, but none of these could be used to treat sediments in river. A breakdown of these technologies by applicability and stage of development can be found in Table 8—2. Only two processes, KOHPEG and NaPEG, were found to be applicable as an in—situ solution. This in—situ solution refers only to those sediments that are exposed (not covered by water), as is the case with the remnant deposits. For all of the other treatments the sediments must first be exposed——by dredging or by river—level reduction——and treatment takes place after dewatering. In addition to the In—river containment systems previously discussed, a new containment option will be considered. This in—place capping option has been 8—16 ------- TABLE 8-2 TECHNOLOGY STATUS AND APPLICABILITY Applicability Status Can be used in Not Applicable connection with for Sediment Contaminated Sediments Decontamination Laboratory Developmental Production Acurex X X Biological Systems X x Controlled Air Incinerator X x Fluidized Bed Incinerator X x Goodyear x Hydrothermal X x KOHPEG X x LARC X X Molten Salt Incinerator X x NaPEG X x Ozonation X X PCBX X x Photodecompositlon X X Plasma Arc X x Pyromagentics Incinerator X x Rotary Kiln X x Thagard HTFW x x Ultraviolet/ozone X x Wet Oxidation X X ------- proven useful in deep as well as shallow ocean waters. The method, discussed in a study presented to the U.S. Army Corps of Engineers, states that a sand cap placed over the ocean bottom will provide good stability to covered sediments even during very high energy conditions (O ’Connor, December 1982). An in—river application of the method would be accomplished by placing a layer of sand over contaminated river bed sediments. The placement of a cover would be accomplished to immobilize PCB—contaminated sediments by preventing their movement through the river system, and preventing the interchange of sediments and accompanying organic material with the water column. The uncertainty associated with this methbd is its applicability to a dynamic river system, especially when considering the thickness of the cover needed (4 feet). Another new alternative considered was in—river solidification. This process involves the mixing of contaminated sediments with a thermoplastic, cementitious or resinous material for in—place (under water) containment. The layering of this material over the contaminated sediments for erosion control was also considered. 8.3 Review of Possible Combinations of Alternatives The combination of remedial alternatives for PCB—contaminated sediments allows for the maximization of an effective solution. This initial review of the alternative combinations will incorporate only the general aspects of compatability and effectiveness. After an evaluation and preliminary screening (Section 8.4), the remaining alternatives and combinations •f alternatives will undergo an in—depth analysis according to criteria outlined in the National Contingency Plan, as will be discussed in Section 9 (NCP, Federal Register , 1982). In keeping with previous discussions of alternatives, a review of alternative combinations for river sediments (40 hot spots) and remnant deposits will be treated as separate and independent actions. 8—18 ------- 8.3.1 River Sediments The alternatives discussed in this section will include those combinations applicable to contaminated riverbed sediments. 8.3.1.1 Detoxification of River Sediments In Combination with Control of River Flows The control of river flows would be accomplished to allow for the maximum exposure of river sediments throughout numerous reaches of the Hudson. By lowering the river level in a reach, many of the hot spots would become exposed and an in—situ detoxification method could be applied. Thern reasoning behind the need to lower the river levels is that there are no in—Situ detoxification methods available that will work in an underwater environment. B constructing (or reconstructing) numerous dams on the river and adding flow control gates, water levels could be controlled to any desirable level. Unexposed sediments would not be removed under this alternative because of the detoxification limitations. The same dams——and additional upstream dams——would later be used to control river flows so that the remaining contaminated sediments would not undergo transport due to high river flows. 8.3.1.2 Dredging In Combination with : • Control of River Flows River flow controls would be undertaken with similar objectives as those for the previous method. With this alternative the exposed sediments would be removed before treatment and/or landfilling. Conventional river dredging techniques could be employed for the unexposed sediments, while a dragline would be used to remove the exposed sediments. The advantage to be gained by this combination will be an increased access to the sediments, and the facilitated removal of 8—19 ------- dried sediments (lower volume) by the more efficient dragline. The control of river flows can be used in connection with the bank—to—bank, 40 hot spot, or reduced—scale dredging alternative. • In—River Containment This pairing should optimize the use of the dredging and containment alternatives; however, the bank—to—bank dredging alternative will not be considered, for obvious reasons. Wetland and shallow (a maximum depth of 6 feet below mean river stage) hot spots would be contained by the use of barriers, etc., and the deeper sediments (where this containment is not possible) would be dredged and the spoils removed from the system. The advantage to be gained by this method is a cost savings realized by the use of in—river containment methods instead of an initially more costly dredging program. A ma]or drawback to the use of the containment alternative is that there will be a continual maintenance cost associated with each contained area. 8.3.1.3 Control of River Flows in Combination with In—River Containment In—river containment would——as stated in the previous alternative——be used for those hot spots located in the shallow (6—foot or less) areas along the banks and islands of the Hudson. In addition, a river flow control program would be instituted to reduce river velocities during periods of high river flows. This would serve to prevent or reduce contaminated sediment transport during periods of high river flows. To accomplish this, a system of up—river dams (new and existing) would be used to control high river flows. By adjusting the drawdown of the reservoirs during low flow periods to increase retention capacity, high flows could be reduced by holding back some of the flow in the dam pool (Draft EIS, 1981). Because a large dredging project would not be needed, a significant savings could be realized in this area; however, the modification of existing dams and the construction of new dams would prove to be a very expensive procedure. 8—20 ------- 8.3.1.4 Multiple Combination of Partial Dredging, Detoxification of Spoils, Control of River Flows, and Partial Containment By implementing each component of the alternative in its most productive and efficient way, a significant cost savings could result. While containment practices could most efficiently be used in the shallow areas (6—foot water levels or less), dredging could be more effectively used for deeper river sediments. To facilitate the removal and containment processes, a river flow control program could be implemented as discussed in previous sections. Finally, the removed sediments would be detoxified, thus eliminating the need for a secure landfill. 8.3.2 Remnant Deposits The alternatives discussed In this section wIlt include those combinations applicable to contaminated remnant deposit sediments. 8.3.2.1 Partial Removal of Remnant Deposits in Combination with : • In—Place Containment For this alternative, the most highly contaminated sediments would be removed. The remaining remnant deposits would be contained in—place. This combination would remove the hlghestconcentrations of PCBs while containing those areas where the health risk is not as severe. The advantage to be gained here would be a cost savings associated with the reduction of truck trips needed to relocate the contaminated sediments. • Restricted Access This alternative is similar to the previous alternative in that the highly contaminated sediments would be removed, but the difference would be that the remaining sediments would not be contained. Measures would be taken at the remaining areas that would limit or prohibit access to these areas by the public or wildlife. 8—21 ------- • Detoxification In—place detoxification of sediments with PCB concentrations greater than 50 ppm would be accomplished with the KOHPEG or NaPEG methods, and the other contaminated sediments would be removed from the sites. 8.3.2.2 In—Place Containment in Combination with : • Restricted Access With the addition of public access restrictions to contained and uncontained areas, the problem of potential contact with contaminated sediments should be greatly reduced. Those remnant areas with PCB concentrations of 50 ppm and above would be contained using methods described in Section 8.1. Security fences and warning signs would be constructed around all of the remnant areas——contained or otherwise——to limit public and wildlife access to the site. • Detoxification In—place detoxification of sediments with PCB concentrations greater than 50 ppm would be accomplished with the KOHPEG or NaPEG methods. After detoxification, the sediments would be solidified or contained by dikes or berms on site for an environmentaIly safe and cost— effective solution. 8.3.2.3 Restricted Access in Combination with Detoxification Those remnant deposits that are located above the river level would be detoxified using the KOHPEG or NaPEG methods. Those areas that cannot be detoxified or have PCB concentratior s of less than 50 ppm would be restricted to public and wildlife by fencing and posting of warning signs. 8—22 ------- 8.3.2.4 The Combination of Removal, Restricted Access, and Detoxification For this alternative, the sediments having PCB concentrations greater than 50 ppm would be removed, treated (either incinerated, or detoxified), and either landfilled or replaced. The final approach to the problem would be to limit all public and wildlife access to the remaining sediments with fences, barriers, and signs. 8.3.2.5 The Combination of Removal, Restricted Access, and Partial Containment Removal of the most highly contaminated (50 ppm PCB and over) sediments from the remnant areas would be the initial phase of the in plementation of this alternative. The remaining sediments——those that would be too difficult or expensive to remove——would be stablized by using those methods discussed in Section 8.1.1.5. The final measure taken would be by fencing and posting signs around the areas to limit public or wildlife contact with these sediments where contaminated sediments remain. 8.3.2.6 The Combination of Removal, Restricted Access, Detoxification,, and Partial Containment This alternative combination would be similar to the previous alternative except that the removed sediments would be treated or detoxified by one of the methods described in Section 8.2. Other areas——less contaminated——could be either contained or detoxified as dictated by cost or Implementation problems. Finally, all areas where contaminated sediments remain would be fenced and posted (except for remnant area number 1) to limit access, except for remnant area number 1) which is located in the middle of the river. 8.4 Preliminary Screening of Alternatives An initial screeiiing of alternatives is required in order to eliminate obviously infeasible or inappropriate technologies from consideration as viable remedial actions. The remaining alternatives will then undergo a detailed evaluation in order to determine the cost—effective alternative. 8—23 ------- The NCP has established three criteria for the initial screening of remedial alternatives: • Acceptable engineering practices • Effects of the alternative • Cost A flow chart of the proposed screening process is presented in Figure 8—1. In the technical screening phase, all infeasible, unapplicable, or unreliable technologies will be eliminated. The remaining alternatives will then enter the environ mental/public health/institutional (i.e., social concerns, legal concerns, etc.) screening phase, where technologies that have significant adverse effects or do not contribute substantially to the protection of health, welfare, or the environment will be eliminated. This includes all remaining technologies/alterna- tives whose costs are relatively expensive and do not offer substantial benefits. Alternatives which have passed the previous screenings will enter into a much more detailed evaluation/cost analysis. 8.4.1 Screening of Detoxification or Destruction Techniciues Because the majority of the following technologies are still in the early stages of development, little information is known about the environmental effects and cost of each alternative. Acceptable engineering practices were weighted the highest during the screening, with an advantage going to those processes that are fully developed or nearly so. EPA screening criteria state that any alternative that relies on unproven technology will be rated low. Those alternatives which passed the initial screening process are further discussed in Chapter 9. • Acurex — removed from further consideration This process, although available for use, is difficult to implement and is not permitted by the EPA for use on PCB—contaminated sediments. • Biological Destruction — removed from further consideration 8-24 ------- INFEASIBLE, NOT APPLICABLE, AND UNRELIABLE TECHNOLOGIES EXPENSIVE TECHNOLOGIES OFFERING SAME OR LESSER BENEFITS OFFER ADEQUATE PROTECTION FLOW CHART OF INITIAL SCREENING PROCESS HUDSON RIVER PCB SITE, HUDSON RIVER, NY NUB _CORPORA ON 0 A Halliburton Company (7 ’ STEP 2 ENVIRONMENTAL; PUBUC HEALTh; INSTITUTIONAL SCREENING TECHNOLOGIES ThAT HAVE ADVERSE EFFECTS OR DO NOT REMEDIAL ALTERNATIVES FIGURE 8 -I ------- Because this system has not proven itself effective for use on the highly chlorinated biphenyls, it will not undergo any additional evaluation. • Goodyear — removed from further consideration This process is non—mobile and is difficult to use in conjunction with contaminated sediments, and therefore has been removed from further evaluation. • Hydrothermal — removed from further consideration Because work on this process is still in the early developmental stage, it would not be available in the near future for use with Hudson River sediments. • KOHPEG — passed initial screening Although testing has not been completed for this process, the EPA is optimistic that this process will be effective. It is being included in the final screening since it may be approved as a result of field testing by the time this RAMP is implemented. • NaPEG — removed from further consideration This process would involve similar costs and effects as the KOHPEG process, but it is not as reactive and is more sensitive to impurities; thus it was removed from further evaluation. • PCBX — removed from further consideration The PCBX system has not been approved by the EPA for use on PCB— contaminated sediments. In addition, the fact that the process requires a solvent extraction of the sediments poses difficulties for onsite implementation and thus removes this technology from further evaluation. 8-26 ------- • Plasma Arc removed from further consideration This process Is still in the laboratory stage, and is thus considered too preliminary for use with this project. • Pyromagnetics Incinerator — removed from further consideration. This process is currently relying on unproven technology, and the existing unit is too small to be useful for the large volumes of Hudson River sediments. • Rotary Kiln — passed initial screening • Thagard HTFW reactor — removed from further consideration Because this reactor Is a non—mobile unit, the associated high operating costs preclude further evaluation of this technology. • Wet Air Oxidation — passed Initial screening 8.4.2 Screening of Single Alternatives 8.4.2.1 In—rIver Sediments • Dredging — bank—to—bank — removed from further consideration Bank—to—bank dredging would be difficult to implement, would incur large capital costs, and would be destructive to the ecology of the river. It was eliminated on this basis. • Dredging — 40 Hot Spots — passed initial screening • Dredging — Reduced—Scale — passed initial screening 8-27 ------- • In—river Containment — removed from further consideration The containment option offers no advantage over the dredging option and. after implementation, has more drawbacks. Although the initial costs associated with in—river containment are approximately equal to that of • dredging, maintenance and monitoring costs would continue and would perpetually add costs to the project (DE 1S, 1981). Although experimental capping of contaminated mud deposits with clean sediments and sand in the New York Bight has proven successful (O’Conner, 1982). capping of contaminated deposits in a river system has not been studied. Three problems would hamper the use of such an alternative in the Hudson River. First, uncontaminated sediments and sand would have to be transported a great distance since any such material found above Glens Falls is not accessible by barge, and suitable material may not be available downstream in the Hudson River. Secondly, future maintenance dredging could disturb the liner over many of the larger hot spots. Only a few isolated wetland hot spots would be suitable. Thirdly, silt and sand would not provide enough protection against scour and, therefore, large volumes of expensive gravel and stone would be required. For this reason in—river containment will not undergo further evaluation. • Control of River Flows — removed from further consideration The cost of constructing the numerous dams necessary for this program was considered too expensive for the limited benefits produced. • No—Action — routine dredging ceases — removed from further consideration Although this would be a cost—effective solution, the economic losses would be too great after the cessation of commercial shipping in the river as a result of sediment—blocked channels. 8—28 ------- • No—Action — routine dredging continues, with water treatment passed initial screening • No Action — routine dredging continues, without water treatment — passed initial screening 8.4.2.2 Remnant Deposits • Removal — total — passed Initial screening • Removal — partial — passed initial screening • Detoxification — In—situ — passed initial screening • In—place Containment — passed initial screening • Restricted Access — passed initial screening • No Action — passed initial screening 8.43 Screening of Combinations of Alternatives 8.4.3.1 River Sediments • Detoxification in combination with control of river flows — removed from further consideration Although the detoxification of river sediments exposed by low river levels is possible, the construction of enough dams to accomplish this project would be cost prohibitive. • Dredging in combination with control of river flows •— removed from further consideration 8—29 ------- The decision to remove this alternative from consideration was based upon excessive construction costs. Included in this screening were all three alternatives for dredging: bank—to—bank, 40 hot spot, and reduced— scale. • Bank—to—bank dredging in combination with in—river containment —removed from further consideration Bank—to—bank dredging has been removed from consideration during the initial screening of alternatives as too costly a project. • Dredging of the 40 hot spots in combination with in—river containment — removed from further consideration Because the in—river containment option offers no advantage over dredging——as discussed before——this alternative will not be evaluated further. • Reduced—scale dredging project in combination with in—river contain- ment — removed from further consideration In—river containment would offer no advantage over dredging for a reduced—scale project as well as the full—scale project. This alternative was therefore removed from consideration. • Control of river flows in combination with in—river containment — removed from further consideration The control of river flows alternative has been eliminated as a non—cost— effective alternative. • The combination of partial dredging, control of river flows, and partial containment — removed from further consideration 8—30 ------- This alternative will no longer be considered due to the removal of the control of river flow alternative. 8.4.3.2 Remnant DeDosits • Partial removal in combinatioi with In—place containment — passed initial screening • Partial removal in combination with restricted access — passed initial screening • Partial removal in cOmbination with detoxiflcatio n (in—Situ) — passed initial screening • in—place containment in combination with restricted access — passed initial screening • in—place containment in combination with detoxification (in—situ) — passed initial screening o Restricted access in combination with detoxification (in—situ) — passed initial screening • The combination of partial removal, detoxification (in—situ), and restricted access — removed from further consideration This alternative was removed from further consideration because there is not enough information available at this time about the location of PCBs to determine where each technique would be appropriate. • The combination of partial removal, partial containment, and restricted access — removed from further consideration Removed by the same reasoning as discussed above. 8—31 ------- • The combination of partial removal, detoxification (in—situ), partial containment, and restricted access — removed from further consideration Removed by the same reasoning as discussed above. 8—32 ------- 9.0 EVALUATION OF ALTERNATIVES 9.1 Methodology for Evaluation of Alternatives After completion of the initial screening of alternatives, a detailed evaluation of the remaining alternatives was conducted In order to recommend a cost—effective alternative. The cost—effective alternative is the lowest cost alternative that is technologically feasible and reliable and which effectively mitigates and minimizes damage to and provides adequate protection of public health, welfare, or the environment (47 Federal Register 137). A trade—off matrix was used for evaluating the cost—effectiveness of the remedial actions. The candidate alternatives were rated according to several measures of effectiveness and cost. Weighting factors were applied to the various measures as a technique to assign relative i17%portaflCe to each measure. The final scores (sum of ratings times weighting factors for the cost and effectiveness measures) were then compared in order to determine the recommended alternative. 9.2 Criteria for Evaluation of Alternatives 9.2.1 Effectiveness Measures The critical components of effectiveness measures were determined to be: technical feasibility as well as public health, Institutional, and environmental effects. Particular emphasis was placed on the following: Technical FeasibIlity — Proven or experimental technology — Risk of failure 9—1 ------- • Public health effects — Reduction of health and environmental impacts — Degree of cleanup • Institutional effects — Legal requirements, Institutional requirements - Community impacts — Impacts on fishing, navigation, and generation of hydroelectric power — Approval of land use • Environmental effects — Impact of failure — Length of time required for cleanup — Amount of- environmental contamination with respect to acceptable levels Based on these components, a set of independent effectiveness measures were synthesized, as follows: • Technology Status • Risk and Effect of Failure • Time Required to Achieve Cleanup/Isolation • Ability to Meet Public Health & Environmental Criteria • Degree of Cleanup/Isolation Achievable • Ability to Meet Legal and Institutional Requirements • Ability to Minimize Community impacts • Commercial impacts 9—2 ------- 9.2.1.1 Technology Status Technologies involved in a remedial alternative are either proven, widely used, or experimental when applied to uncontrolled hazardous waste sites. Generally, a proven and widely used technology is to be rated highest, and experimental technologies lower. For some specific pollution problems, the only technology available for use at uncontrolled sites may be In the experimental stage. In such a case, an experimental technology may be chosen as cost—effective If It Is highly rated with respect to the other effectiveness measures. Special attention should be paid to whether experience, in other less demanding situations is applicable to a remedial action situation. 1 9.2.1.2 RIsk and Effect of Failure The risk factor is the product of the probability of failure and the consequences of such a failure. A high risk is associated with high probability of failure and significant impacts. At most uncontrolled hazardous waste sites, a no actIons alternative would be considered a high risk. Alternatives with a low probability of failure and relatively minor potential Impacts resulting from failure are considered low—risk alternatives. 1 9.2.1.3 Level of Cleanup/Isolation Achievable In the context of this .methodology, cleanup implies that pollutants are removed from the site and/or the environment by the remedial action alternative. Isolation means that the transport of pollutants from the site to the environment Is stopped or slowed. 1 1 This definition has been extracted from a methodology manual entitled Evaluating Cost—Effectiveness of Remedial Actions of Uncontrolled Hazardous organizing cltzens’ groups to review the remedial action, seeking legal advice, and attending public meetings. 9—3 ------- 9.2.1.4 Ability to Minimize Community Impacts A community impact is broadly defined as any change in the normal way of life which can be directly or indirectly attributed to the execution of the remedial action. These changes Include those actions which people would not normally undertake, such as moving permanently from a condemned property, moving to temporary lodging during the remedial action, or undergoing health monitoring. The above impacts are in some cases merely a source of irritation to a community. However, some possible community impacts are clearly negative, such as increased noise during the action, traffic congestion, loss of access to the site or to roads near the site, decline in property values, and stress related to all of the above and to uncertainty about health risks. 1 9.2.1.5 Ability to Meet Relevant Public Health and Environmental Criteria This measure compares the remedial alternatives in terms of how well they attain relevant public health and environmental standards such as those under the Safe Drinking Water Act, Clean Water Act, or Clean Air Act. Alternatives would be compared on level of attainment rather than just attainment or non—attainment. 1 9.L1.6 Ability to Meet Legal and Institutional Requirements This measure assesses the ability of a given remedial measure to meet requirements of local, State, and Federal permits; and suitability of the measure to meet other pertinent legai requirements. 1 This definition has been extracted from a methodology manual entitled Evaluating Cost—Effectiveness of Remedial Actions of Uncontrolled Hazardous Waste Sites produced by the Radian Corporation, Austin, Texas, in 1983. 9—4 ------- 9.2.1.7 Time Required to Achieve Cleanup/isolation The time required for a remedial action alternative to achieve its designed degree of cleanup or isolation may range from weeks to many years, depending on the technology and site conditions. 1 9.2.1.8 Commercial Impacts This measure evaluates the impacts of the remedial alternatives on the commercial environment of the Hudson River. important factors may include the effects on transportation, fisheries, public water supplies, hydroelectric power generation, future construction, and agriculture. 9.2.2 Costs According to CERCLA, a total cost estimate for a remedial action must include both construction costs and annual operation and maintenance costs. .The Total Construction Cost can be defined as the sum of the Total Direct Capital Cost and the Total Indirect Capital Cost (Radian Corp.. January 1983). Direct capital costs may Include the following cost components: Construction Costs — Components include equipment, labor (including fringe benefits and workman’s compensation), and materials required to install a remedial action. Equipment Costs — In addition to the construction equipment cost component, remedial action and service equipment should be included. Land and Site—Development — Costs include land—related expenses associated with purchase of land and development of existing property. Buildings and Services — Costs include process and non—process buildings and utility hook—ups. 9—5 ------- Indirect Capital Costs may include the following components: Engineering Expenses — Components will include administration, design. construction surveillance, drafting, and testing of remedial action alternatives. Legal Fees and License/Permit Costs — Components will include administrative and technical costs necessary to retain licenses and permits for facility Installation and operation. Relocation Expenses — Relocation expenses should include costs for temporary or permanent accommodation’s for affected nearby residents. Start—up and Shake—down Costs — Costs incurred during remediai action start—up for long—term activities should be Included. Contingency Allowances — Contingency allowances should correlate with the reliability of estimated costs and experience with the remedial action technology. The operation and maintenance cost may include the following components: Operating labor costs — Include aD wages, salaries, training, overhead, and fringe benefits associated with the labor needed for post—construction operations. Maintenance materials and labor costs — Include the costs for labor, parts, and other materials required to perform routine maintenance of facilities and equipment for the remedial alternative. Auxiliary materials and energy — Include such items as chemicals and electricity needed for treatment plant operations, water and sewer service, and fuel costs. Purchased services — include such items as sampling costs, laboratory fees, and professional services for which the need can be predicted. 9—6 ------- Disposal costs — Costs should include transportation and disposal of any waste materials, such as treatment plant residues, generated during remedial operations. Administrative costs — Cover all other O&M costs, including labor—related costs not included under that category. Insurance, taxes, and licensing costs — Include such items as: liability and sudden and accidental insurance; real estate taxes on purchased land or right—of—way; licensing fees for certain technologies; and permit renewal and reporting Costs. Maintenance reserve and contingency funds — Represent annual payments into escrow funds to cover anticipated replacement or rebuilding of equipment and any large, unanticipated O&M costs, respectively. 2 Construction costs and operation and maintenance costs were estimated for the above criteria. For operating and maintenance costs, a present—vaIue analysis was used to convert the annual costs to an equivalent single value. Operation and maintenance costs were considered over a 20 year period; a 10 percent discount rate and 0 percent inflation rate were assumed. For the Hudson River PCBs Site, costs for an environmental monitoring program were included as operation and maintenance costs where appropriate. Estimated costs and supporting calculations are included in Appendix C. 9.2.3 Weighting Factors Weighting factors were previously defined as a means of assigning relative Importance to the cost and effectiveness measures. A high weighting factor, which identifies an Important measure, increases the effect of that measure with respect 2 The above definitions have been extracted from a draft Superfund Feasibility Study Guidance Document compiled by .,JRB Associates. McLean. Va., 1983. 9—7 ------- to the final evaluation. Correspondingly, a low weighting factor reduces the effect of a “low Importance” measure with respect to the final evaluation. Selected weighting factors are presented in Table 9—1. WeightIng factors were developed by an internal technical group using EPA guidance documents. It was the decision of the evaluation committee that operation and maintenance costs were more critical to the final ranking than construction costs. Correspondingly, a higher weighting factor was assigned to operation and maintenance costs (1.2) than to construction costs (1.0). s.3 Evaluation of Alternatives • 9.3.1 ExamInation of Remaining Alternatives Alternatives which passed the Initial screening were further examined/developed so that the alternatives could later be evaluated with respect to each of the previously discussed effectiveness measures. These examinations are summarized in the following subsections. 9.3.1.1 Remedial Alternative: Detoxification of Removed Sediments with KOHPEG Description: Potassium hydroxide (KOH) and polyethylene glycols (PEG) react with and destroy polychlorinated biphenyls (PCBs), producing reaction products of aryl polyglycols and biphenyls. The presence or absence of air apparently has little effect on the reaction. Reaction time Is reduced with increased temperature; however, the reaction will proceed under ambient conditions. KOHPEG has not been .applled in the field to soils containing PCBs, but application to dredged sediments conceptually might proceed as follows. The dredged material would be placed in a lagoon for dewatering to a suitable water content level. The water would be decanted, tested, and possibly treated before discharge. Dredging would only proceed until the calculated depth of dewatered sediments would not 9—8 ------- TABLE 9-1 WEIGHTING FACTORS FOR EFFECTIVENESS MEASURES Effectiveness Measures and Costs Weighting Factors Technology Status 0.6 Risk & Effect of Failure 1.1 Level of Cleanup! IsolatIon Achievable 1 .0 Ability to Minimize Community Impacts 0.6 Ability to Meet Relevant Public Health and Environmental Criteria 0.6 Time Required to Achieve Cleanup/Isolation 0.5 Ability to Meet Legal and Institutional 0.5 Requirements Commercial Impacts 0.4 Construction Cost 1 .0 Operation & Maintenance Cost 1.2 9—9 ------- exceed the effective treatment depth of one application of KOHPEG. Dredging would be staged to meet this requirement. An initIal assumption of a one foot depth could be made. KOHPEG could then be sprayed over the area, followed by rototHling. The application rate would be a weight of reagent equal to 6 percent of the weight of the removed sediment being treated. One fuii summer should be allowed for the reaction to proceed. Testing could then be done to determine whether the PCBs have been destroyed. The sequence of operations could then be repeated, with the dredged sediments being placed over the decontaminated sediments. Adjustments in the amount of dredging, application rate, and rototilling on subsequent cycles could be made, based upon the results of the previous cycle. An alternative method could also be used. The dredging could be completed In one operation, with all material going to a lagoon for dewatering. The destruction of PCBs would then follow the plan for the remnant deposit sites. in summary, this would be the application of KOHPEG, rototilling, testing to determine the depth at which the PCBs had been destroyed, excavating that material, and then repeating the sequence until the full depth of dredged sediments had been treated. Applicability: The detoxification of contaminated materials with KOHPEG could be applicable to river sediments having a high PCB concentration. Technology Status: The KOHPEG system is still in the laboratory stage, where work that has been done on PCBs contained in transformer oils and soils seems to show promise. Laboratory work indicates that PCBs contained In soils with significant organic content will be destroyed, but may take several months. The treatment system will tolerate some water In the soil, but the limit has not been established. Use on dredged sediments will require testing to establish the limiting water content level. A field application test Is expected to begin in the summer of 1984, and it is estimated that 12 to 18 months will be required for development of techniques for large—scale application. Additional research is required to establish dilution ratios for the reagent, dosage rates, and methods of application and to develop procedures that will assure contact of the reagent with the contained PCBS. 9—10 ------- Risk and Effect of Failure: The probability of failure of KOHPEG is dependent upon the degree to which the solution comes in conta t with the PCBs. Assuming the solution is rototilled into the sediments properly, the PCBs should become detoxified and, hence, present no risk to the public. Should this assumption prove invalid, the sediments will remain hazardous and must be treated as such. Time Required to Achieve Cleanup/Isolation: It may take several months for the reagent to destroy the contained PCBs, and the speed of the reaction Increases with increasing temperatures. It follows that it will likely require at least one summer season for destruction of PCBs in a treated area. it is unlikely that all sediment areas would be dredged at the same time, and dewaterlng before treatment may be required. In addition, the time required to treat all dredged sediment areas to the full depth of contamination will depend upon availability of adequate quantities of reagent and upon the manpower commitment to treat several areas concurrently. It is not possible at this time to predict the total elapsed time. Ability to Meet Public Health and Environmental Criteria: Acute toxicity tests have been performed on the reaction products which result from the destruction of PCBs in transformer oils. The products were found to have no biological activity other than being a mild eye irritant, but no long—term biological tests have been performed. Polyethylene glycols in the laboratory have been degraded by anaerobic bacteria. It is expected that reaction products will be biodegradable since they contain oxygen. Analyses of transformer oil and the reaction products after treatment of PCB contaminated transformer oil were unable to detect PCBs, polychlorinated dlbenzofurans (PCDF) or polychlorodibenzodioxins (dioxins). Degree of Cleanup/isolation Achievable: Using this method, essentially 100 percent cleanup of the contaminated sediments can be obtained. AbilIty to Meet Legal and Institutional Requirements: The treatment process may require a Hazardous Waste Management Facilities permit as well as a National Pollution Discharge and Elimination System (NPDES) permit for the discharge of decanted water. Additional State permits may be required for the construction of 9—11 ------- treatment facilities and the transport, discharge, and disposal of hazardous wastes. Local building permits may also be required for land use. Ability to Minimize Community impacts: This process will minimize community Impacts if no digging of the dredged sediments is required for the reagent to contact all contained PCBs. There may be some volatilization of PCBs if the soil requires rototilling, but it should be minimal. No transport or treatment off site would be required. Commercial impacts: The periodic dredging of sediments may interrupt traffic on the river. Once the treatment is completed; however, the river will eventually be restored to a less contaminated state. This will enable it to be used once more for recreation and commercial fishing. Costs: Detailed costs were estimated and are included in Appendix C. 9.3.1.2 Remedial Alternative: Detoxification of Removed Sediments with Wet Air Oxidation Description: Wet air oxidation (WAD) is a commercially proven technology for the •destruction of organics in wastewater and sludges; however, it is expected that higher temperatures and pressures will be needed to destroy more environmentally persistent chlorinated organic compounds. This difficulty apparently can be overcome with the use of catalysts. WAO using catalysts will destroy chlorinated compounds, such as PCBs, at relatively low temperatures, and will oxidize essentially all organic materials. In this application, the dredged sediments would have to be routed to a storage basin because the dredge removal rate to attain an optimum solids and organic content likely will exceed the WAO processing rate. As the organic content of the waste increases, the amount of external heat required in the reaction is reduced. However, the slurry needs to be fluid In order to be handled try the reactor. Literature reports that the process can be self—sustaining at organic concentrations which range from 1 to 4 percent. Actual sediment analyses show an average 9—12 ------- organic content of 5 percent on a dry—weight basis. Since dredging typically provides a material with a solids content of 10 to 30 percent, as removed dred ed material will have an organics content of 0.5 to 1.5 percent. The high end of this range appears to be adequate for sustaining WAC without using external energy for heating and is judged to be a pumpable slurry. Therefore, it is likely that the storage basin would have to be mixed in order to maintain a pumpable slurry. For cost estimating purposes, it was assumed that the basin Inlet and slurry discharge to the WAC process will be about 25 percent solids and have an organic content of 1.25 percent. The slurry will be pumped into a continuously stirred tank reactor containing the catalysts. Here, the air is sparged into the reactor to oxidize organics, with the heat of reaction driving off water. The developer of the open system indicates that catalyst poisoning has not been observed. The destruction products of PCBs are water, carbon dioxide, lower volatile acids, and inert solids. A heat exchanger will be used to preheat feed slurry. Condensed steam may Contain oxidation product intermediates and thus may require further polishing before discharge. Solids removed from the reactor should be inert if process performance can be optimized; however, further testing will be required to assure that a suitable disposal option is employed. Applicability: Catalyzed WAO is applicable to the destruction of chlorinated organics contained in slurries or sludges, although pilot work on PCBs In such materials has not been done. Technology Status: The work on WAO as applied to PCBs has been on a laboratory scale only. It is believ.ed that catalyzed WAO will destroy PCBs in soil because of success in destroying other chlorinated organlcs. Production units in operation are limited to two units treating 10 gallons per minute of liquid waste containing 40 grams per liter of COD. Units to freat soils containing PCBs could be made portable. Large—scale production facilities for the use intended in this study have not been constructed or tested. Risk and Effect of Failure: A relatively high risk is associated with the implementation of this alternative. 9—13 ------- Time Required to Achieve Cleanup/Isolation: A process design for a 25 gallon per minute unit has been conceptualized. With a slurry containing 15 percent solids, 31 pounds of sediments per minute would be treated. Such a unit operating around— the—clock would process about 100 cubic yards of sediment per day. It is proposed that sufficient WAO units be used in order to maintain a detoxification rate equal to the dredging rate. Therefore, the detoxification process should be completed shortly after completion of dredging operations. Ability to Meet Public Health and Environmental Criteria: Reportedly, catalyzed WAO should completely destroy PCBs contained in soils and thus present no violations of public health and environmental criteria. Testing has not been done on production—scale units to establish the fate of other potentially hazardous materials that might be present In the sediments before treatment. Degree of Cleanup/Isolation Achievable: Catalyzed WAO should completely destroy the PCBs contained in the river sediments. Ability to Meet Legal and Institutional Requirements: The treatment process may require a Hazardous Waste Management Facilities permit as well as an NPDES permit for the discharge of decanted water. Additional State permits may be required for the construction of treatment facilities and the transport, discharge. and disposal of hazardous wastes. Local building permits may also be required for land use. Ability to Minimize Community Impacts: There will be no transport or spill Impact on the community because the sediments will not be transported off site. The potential for possible air contamination by materials other than PC9s contained in the sediments is unknown. Disposal of dredged sediment after application fo the process should present no problems since It could be used as clean fill. etc. Commercial Impacts: Once the treatment is completed, the river will eventually be restored to a less contaminated state. This will enable it to be used once again for commercial fishing and recreational purposes. 9-14 ------- Costs: Detailed costs were estimated and are included in Appendix C. 9.3.1.3 Remedial Alternative: Destruction of Removed Sediments by Incineration Description: In order to develop the costs for this alternative, an incineration system which is technically feasible has been proposed. it includes the following operations: de—watering of the influent, batch feeding of the solids into the incineration unit, incineration, disposal of the residue, and air pollution control. The original design of the system uses a movable incinerator with the thought that this may minimize transportation costs of the dredge spoils. A movable rotary kiln has been selected which could be either batch fed or continuously fed. Since the possibility of installing the unit on a barge is also under consideration, the decision was made to use the batch—feed option. Some coagulation and dewatering procedures have been included in order to put the dredge spoils slurry Into a form suitable for incineration. The residue expected after incineration would be a sterile, clean material. Applicability: This process is applicable to processing dewatered sediments or remnant deposits which contain adsorbed PCBs. Technology Status: This technology has been in use for years and is considered to be standard technology. Risk and Effect Failure: This risk factor will be low for the following reasons: • In order to provide a common costing basis, the incineration was required to be completed within two years. This resulted in a number of units being used rather than just one. Although the use of multiple units provides a redundancy factor, the result is that breakdown of individual units will not halt the incineration process. • The technology is common, and is not liable to fail. As a result, the proposed system should be considered to be a low—risk alternative. 9—15 ------- Time Required to Achieve Cleanup/Isolation: It is proposed that the Incineration be completed within two dredging seasons; that is. as the sediment is dredged, it Is almost immediately incinerated. The Ability to Meet Public Health and Environmental Criteria: As long as the incineration process Is operated to meet Federal requi ements regarding temperature and dwell time, this alternative will completely destroy the PCBs and the sediments. Degree of Cleanup/Isolation Achievable: The incineration alternative should completely eliminate the PCB’s in the sediments incinerated. Ability to Meet Legal and Institutional Requirements: The treatment process may require a Hazardous Waste Management Facilities permit as well as an NPDES permit for the discharge of air pollution control water and water from the de— watering process. Additional State permits may be required for the construction of treatment facilities and the transport, discharge and disposal of hazardous waste. State and/or Federal permits may be required for the air emissions. Local building permits may also be required for land use. Ability to Minimize Community Impacts: Since multiple units will be required, a number of sites can be located along the river. This would minimize transportation of waste on the roads and reduce community Impact. However, there will be Increased noise as a result of the operation of the incinerators. In addition, there will also be increased traffic required by delivery of supplies and fuel, and removal of the incinerated residue to an unsecure landfill. There may also be some air pollution due to dust and steam from the incineration operations. Commercial Impacts: This alternative will result in complete elimination of the PCBs. It will reduce the requirements for disposal capacity to approximately one third of that needed for disposal of non—incinerated dredge spoils. In this way the amount of agricultural land taken out of service will be reduced. 9—16 ------- Costs: Detailed costs were estimated and were included in Appendix C. 9.3.1.4 Remedial Alternative: Secure Landfill Disposal of Removed Sediments Description: This alternative includes siting, design, construction, operation, closure and post—closure monitoring and maintenance of a single, multi—celled, controlled access, dredged, PCB—laden sediment landfill. According to Malcolm Pimie, Inc., Containment Site No. 10, near Fort Edward, New York, appears to be the most favorable site (see Figure 4—3). The basic design, construction, operation, closure, and post closure monitoring and maintenance are described by Malcolm Pirnie, Inc. (September 1980, Dredging System Report Program No. 2; September 1980, Design Report; September 1981. Contract No. t Containment Site— Specifications) and U.S. EPA (August 1981, Supplemental Draft EIS; October 1982, Final EIS). This alternative provides an encapsulated, stable, dewatered, monitored, and secured containment area which is essentially equivalent to, or exceeds, appropriate regulatory requirements and commonly acceptable engineering practices for PCB landfills. The following is a description of the proposed 250—acre containment site provided by Malcolm Pirnie, Inc.: Containment Area — The containment area is an earthen basin bisected by a cross dike. It occupies appro dmately 63 acres in area at its maximum water surface and its total containment volume at the maximum water surface is 2,260,000 Cu yds. This volume is sufficient to hold all of the 40 hot spot sediments, the remnant deposits, and the DOT spoil areas, If necessary. The containment area will be designed for long—term encapsulation of PCB— contaminated materials, and will therefore be capped with a clay cover after each season of dredging. 9—17 ------- Roughing and Storage Pond — The roughing and storage pond (R&SP) Is an earthen basin with a maximum water surface area of approximately 12 acres. After the slurried dredge material is pumped into the containment area, weir overflow is transported via pipeline to the R&SP. The primary purpose of this basin is to ensure efficient sedimentation near the end of each dredging season as the effective overflow rate In the containment area increases. The R&SP also provides protection for the subsequent treatment units from any upsets in the containment area which might lead to transient escape of dredged material. A small portable dredge will be operated to recycle settled dredgea material back into the containment area. The R&SP is not a permanent containment unit. At the end of the dredging program, all of the contaminated material In the R&SP will be relocated to the containment area and the pond will be filled in and regraded. Surge Pond — The surge pond is an earthen basin with a maximum water surface area of 2.4 acres. This pond receives weir overflow from the R&SP. Its purpose is to buffer the treatment plant units from surges in the dredging process and to provide a convenient, sediment—free point for treatment feed and recycle supply pump suctions if a recycle dredging procedure is Implemented. A detailed discussion of dredging options is presented in the Containment Site Design Report. Water Treatment Plant — The water treatment plant consists of two earthen basins: the flocculation basin and the settling basin, with maximum water surface areas of 0.1 and 1.0 acres, respectively. The planf has a capacity of 13 millIon gallons per day (mgd) and Consists of coagulation, flocculation, and sedimentation units. The purpose of the water treatment plant is to reduce PCB concentration In the dredge return flow before discharge to the rIver. 9—18 ------- The water treatment plant is expected to achieve effluent suspended solids of less than 4 milligrams per liter and turbidity of less than 10 Nephelometric Turbidity Units ( JTU) with proper chemical doses. The average PCB concentration in the discharge is expected to be in the 10—20 microgram per liter range. Pump Station — The pump station consists of three mixed—flow pumps, each with a capacity of 4500 gallons per minute (gpm). One of the three pumps functions as a standby. The pump station’s function is to provide a reasonably constant influent feed to the water treatment plant. - Leachate Collection System — The leach ate collection system is a network of perforated drainage piping laid in gravel—filled, filter—.cloth—lined collection trenches at the base of the containment area. The bottom of the containment area is sloped to transmit flow towards the trenches. The leachate collection system will be utilized in two phases: short—term dewatering and long—term percolation. Valves, collection and sampling wells, and a flow metering and monitoring manhole are provided to determine the quantity and concentration of PCBs in the leachate. Discharge to the Hudson River will only be permitted If the observed leachate quantities and concentrations will have no adverse impact on the river. If river discharge proves unacceptable, the leachate will be collected and treated. Stormwater Drainage System — The stbrmwater drainage system will intercept and convey stormwater runoft that will directly affect the containment site. Runoff on the containment site and from the watershed north of the containment site, will be transported by the drainage system to the Hudson River. The components of the drainage system entail a combination of swal s, open channels, and closed conduits. g—i 9 ------- Access Road — An access road will be provided between Route 4 and the chemical feed building. This roadway will permit access to tank trucks delivering bulk chemicals, as well as access and parking for contractor, engineering, and DEC personnel. Chemical Feed System — The pumps, piping, tanks, and dilutIon water needed for the chemical feed system for the treatment of the dredged slurry will be housed in a chemical feed building. Appurtenances — Also included in the construction site requirements are electrical services, fencing, seeding, clearing and grubbing of wooded areas, and establishment of monitoring wells. Applicability: This alternative applies to long—term storage of PCB—Iaden remnants and sediments which are dredged from the Upper Hudson River. The alternative is well suited in this application because of the location and specific siting and design criteria which have evolved during its development. Technology Status: This alternative requires technology which is generally available, routine, and nonexperimental. Key elements, which are surface dewatering, landfill design, treatment of leachate, collection and routing of leachate. and closure and post—closure maintenance, are widely practiced in the management of hazardous waste sites. The IntegratIon of these elements, though not commonly applied to hazardous waste sites because hydraulic loading is generally not a factor, is very commonly applied and Integrated in well—established Industrial waste management Such Industry experience is common for red—mud aluminum waste, papermill waste, and copper mining wastes. Risk and Effect of Failure: This alternative has a very low probability of failure and very low probability of risk, and is therefore an extremely low—risk alternative. This assessment is based on the fact that it is technically feasible to contain and store PCB—laden sediments in a properly designed landfill as proposed. and that the consequences of failure to contain are slight because of site factors, such as abundance of native clay subsoil, and distance to potential health vectors. 9—20 ------- Time Required to Achieve Cleanup/Isolation: The construction of the containment site and treatment plant facilities would occur during the first year of the dredging program. Dredging will begin in the second year and will be completed in the third year. Final cover and regrading of the site and destruction of the earthen dikes for the roughing and storage pond and surge pond will take place in the fourth year. Therefore, the containment of PCB—laden sediments will require a total of four years. Ability to Meet Public Health and Environmental Criteria: This alternative meets or exceeds current approprIate regulatory requirements, environmental standards, and public policies under current enforcement guidelines. These requirements. standards, policies and guidelines are dynamic and subject to future change. Degree of Cleanup/Isolation Achievable: Based upon review of the design for the containment site, the degree of isolation appears to be high to very high. Ability to Meet Legal and Institutional Requirements: This alternative should meet the requirements under RCRA for a PCB landfill. However, the contair ment area as designed will not meet groundwater or liner requirements, because of the proximity to groundwater, and a waiver from the EPA administrator would be required. In addition, a NPDES permit would be required for any discharge from the leachate collection system. State permits may be required for the construction of the containment site and the transport and disposal of hazardous material. Land use may also require local building permits. Ability to Minimize Community Impacts: This alternative has a moderate ability to minimize community impacts. There is current litigation ‘and citizen—group organization, but these are not necessarily negative Impacts. Commercial Impacts: This alternative will have a very low impact on the oftsite commercial sector after completion, with a moderate impact during construction and operation. The site itself would not have wildlife or agricultural value equivalent to Its earlier potential use. 9—21 ------- Costs: Deta iled costs were estimated and are included in Appendix C. 9.3.1.5 Remedial Alternative: Dredging of 40 Hot Spots Description: The alternative addressed In this section is essentially a combination of activities comprising the removal phase of the 40—hot—spot dredging program set forth by NYSDEC in the Draft Environmental Quality Review Document of September 1980. This program called for the use of conventional hydraulic and mechanical dredging systems to achieve the removal of the 40 hot spots which ware identified in the Upper Hudson River. The first year of the program is to be spent resampling and emapping the bottom sediments to afford more accurate and up—to—date hot—spot delineations and sediment characterizations. It is recognized by State officials that it will not always be desirable to dredge contaminated wetlands because of their valuable contributions to river species diversity and bioproduction. Therefore, in the year prior to dredging, an analysis of PCB losses from wetlands due to volatilization, scour, and blouptake is to be made so that the ecological value of wetlands can be weighed against the risks posed by the continued presence of PCBs. In the second year of the program, both hydraulic cutterhead suction dredges and clamshell dredges with mechanical pumpout systems are to be employed In removing the hot spots in the Thompson island Pool. in the third year, the clam shell dredge/hydraulic pumpout system alone is to accomplish the removal of the 20 remaining hoy spots in the Lock 6 through Lock 1 pools. Detailed, contractually binding, mitigating measures designed to limit adverse environmental Impacts and to maximize the efficiency of PCB removal are to be incorporated in the final design specifications. Mitigating measures applicable to dredging and transportation of dredged material include: Hot Spot Delineation-— Additional sediment sampLes would be taken prior to any remedial dredging to better define the depth and areal extent of contamination. The existing sediment PCB data—base is accurate enough 9-22 ------- for planning, but not for implementation of a hot—spot dredging program. The data are fairly complete for the upper pools, but become more intermittent with distance downstream. Additional data are desirable to more precisely define the hot spots in order to ensure accurate removal of contaminated material. • Overcutting — when possible, a removal depth of approximately 36 Inches will be maintained to ensure the removal of all contaminated sediments and to avoid the direct exposure of highly contaminated strata to the water. • Scheduling — Dredging would take place during the low—flow period between May 15 and September 15 (or until higher flows resume in the fall) to minimize-downstream PCB losses. • Operator Precautions, Hydraulic Dredge — PCB losses from the hydraulic dredge would be minimized by contractual control of the cutter and swing speed. • Operator Precautions, Clamshell Dredge — PCB losses from th& clamshell dredge would be reduced by limiting the hoisting speed through the water column, and by positioning the dredge and receiving barge so as to minimize the length of bucket swing about the water. A dredge bucket with a capacity of at I’east 5 cu yd will be specified to ensure the proper depth of cut. Overlapping of dredge cuts will be specified to ensure that contaminated sediments which slough into the previous cut will be recovered. • Hydraulic Dredge Modifications — The feasibility of placing a shroud over the top of the cutter in order to increase suction effIciency and to limit the escape of suspended material will be examined carefully in the design phase. Other innovative approaches, including installation of a dustpan— type head, will be examined. 9-23 ------- • Clamshell Dredge Modifications — Tight seals on the bucket lips will be required. The feasibility of placing a shroud over the top of the bucket or completely enclosing the bucket to reduce washout during hoisting will be assessed in the design phase. • Floating Boom — Where dredging results In a floating scum, a floating boom would be positioned downstream from the work site. The employment of such a boom should not Impede navigation and would be dependent on favorable current conditions. The boom would be cleaned at least daily, and the trapped matenal placed in the disposal site. • Silt Curtain — Where dredgIng results in an extensive surface plume, a silt curtain may be required. The curtain would extend from the water surface to a point midway in the water column. • Marsh Restoration — if it is determined that the benefits of dredging a particular contaminated marsh-hot—spot outweigh the adverse impacts of habitat loss, and one or more.wetlands are removed, marsh restoration may be a feasible mitigating measure. Malcolm Pirnie (1980) has outlined the steps required for marsh replacement following dredging. These steps are summarized below: — Dredged areas would- be filled with uncontaminated sediments to predetermined, above—grade elevation. — Following settling and consolidation, areas would be filled and/or graded to final elevation. — Upstream structures may be required in order to minimize scour downstream silt screens may be needed to minimize sediment loss. — After final grading, nursery—grown stock or sprigs from nearby marshes would be transplanted and maintained for at least one season. 9—24 ------- Malcolm Pirnie noted that replacement plants must be set out at the same elevations that pre—existing or nearby plants of the same species are established. Avoidance of areas subject to high velocity and scour is necessary in achieving successful restoration. Pirnie reported successful regeneration of wetlands with Peitandra virginica (arrow arum), Pontederia cordata (pickerel weed), Sagittaria latifolia (duck potato), Scirpus americanus (American three square), Typha sp. (cattail) and Leersia orvzoides (rice cut grass). All of these species are found in the existing Upper Hudson marshes. • Shoreline Conditions — During the dredging design phase, detailed field studies and analyses will be undertaken to minimize interferences with overhanging trees and to avoid river bank instability. • Hydraulic Dredge Pipeline — Where navigation may be impeded, it would be necessary to submerge the pipeline. • Pipeline Leaks — While small ieak& are inevitable, operation would be stopped immediately if a major leak or a break occurred. • Hydraulic Pumpout of Barges — In order to reduce leakage, welded connections would be used in the pipeline construction, and a check valve installed at the pumpout station to prevent backflow. • Loading of Barges — Sufficient freeboard must be maintained inside the barge to prevent overflow or spillage during transport. Alternatively, a splashboard could be - installed around the top of the barge, permitting complete filling and thereby maximizing productivity. Applicability: This alternative is applicable to contaminated river bottom sediments only. 9-25 ------- Technology Status: Standard mechanical and hydraulic dredging equipment has been in use for years and Is currently used in the study area for routine channel maintenance. The application of conventional dredging equipment for removal of contaminated sediments for a natural waterway has not been tested on a large scale. The Mudcat dredge, a small hydraulic dredge with a horizontal cutting bar, has, in recent years, been successfully employed In removing toxic sludges from industrial waste’impoundments. In the Lower Hudson River, a Mudcat was used to attempt the cleanup of cadmium—contaminated sediment in Foundry Cove . After multiple passes and removal of 5,000 cu yd of sediment, the dredge was found to have removed an estimated 5—6 tons of cadmium, while Ieavin nearly 50 tons still remaining. Dredging by this method was judged to be ineffectual. The Pneuma dredge, a small flexible pneumatic system, has been used to clean up PCB—contaminated sediments from the Duwamish River estuary in Washington. This dredge, in combination with hand dredging, effected 90 percent recovery of 265 gallons of Aroclor 1242. Unfortunately the conclusions of this study are not applicable to Hudson River dredging since the Duwamish problem was one of a fresh PCB liquid spill confined to a relatively small area of soft, fine sediment. Dredging system alternatives have been evaluated by Malcolm Pirnie, Gahagan and Bryan. and WAPORA. and the conclusions were that a combination of cutterhead suction dredging and mechanical clamshell dredging with hydraulic unloading of hopper barges was the most appropriate method available. A brief discussion of each is provided below. Hydraulic dredges mix ambient water with subaqueous material to form a slurry which is pumped through a floating or submerged pipeline to Its destination. Cutterhead suction dredges of the type specified for the program make use of rotating, circular cutter blades at the end of a suction pipe. With the cutterhead, a wide variety of material, from fine silts to decomposed rock fragments. may -be removed. The use of such dredges is advantageous for dredging in the Upper 9—26 ------- Hudson River, where a heterogeneous mixture, including chunks of wood, is expected to be encountered. This system offers the additional advantage of one—time handling of material between the dredging operation and disposal area. Subsequently, large volumes of material are moved economically because of a virtually Continuous operating cycle. Continuous handling also minimizes the potential for accidental spills. One of the technical drawbacks of the suction dredge system is that it requires approximately one booster pumping station for each mile of pipe through which the dredge material must be transported. Under the original program, the operation of the hydraulic system was to have been limited to the Thompson Island pool because of the high costs associated with booster stations and long pipelines needed to connect the proposed containment area with the dredge operation in remote pools. With the availability of the proposed’ containment site in question, the use of hydraulic dredges can be considered for downstream pools, if multiple sites are used. Gahagan and Bryan report that the operation of a single, 16—inch cutterhead suction dredge would require one derrick barge, two 16—inch booster pumps, two bulldozers, one small tug, one tender tug, one fuel barge, one work barge, pipeline, and miscellaneous machinery. Clam shell dredges consist of a barge—mounted crane equipped with a heavy, double—leaved, hinged bucket which is lowered into the sediment. The bucket is then hoisted above the hopper, and excavated material is loaded into adjacent hopper scows for transport to the disposal area. A hydraulic pumpout system is to be used to transfer dredged material from the barge to -the handling area. This is preferable to mechanical handling since It speeds up handling and reduces spillage. To operate the hydraulic pumpout system, the sediment in the hopper scow is mixed either with ambient river water or recycled water from the treatment plant to form a 15 percent slurry. The slurry is then pumped to the handling area. 9—27 ------- The clam shell dredge has the advantages of being easily obtainable and very mobile. When the clam shell dredge/hydraulic pUmpout system is used with recycled treatment plant water, it has the advantage of avoiding the contamination of large volumes of river water. Clam shell dredges are less precIse than hydraulic dredges, and the potential for loss of contaminated material is greater. Clam shell dredge buckets also have problems with penetratIng compacted layers of sediment. These disadvantages can be minimized by a skilled operator and the specified use of certain mitigatIng measures. Under the proposed plan this system would require two clam shell dredges, two work barges, five hopper scows, one 800 hp tug boat. two tender tugs, pumpout and unloading machinery and piping, plus miscellaneous equipment Since all equipment needed is currently available and all mitigating measures and special modifications. require no substantial research and development, the technical feasibility is high. Risk and Effect of Failure: It was contended by NYSDEC and their consultants that this program was the most implementable and cost—effective approach. achieving the greatest reduction in sediment PCB—load per dollar expended and per acre of riverbed exposed. Considering the expected PCB losses during the dredging operation In addition to the uncertainties in PCB recovery due to the hot—spot scour and analytical and sampling variability, the risk of failure to achieve the objective may be moderate. In the tong term, failure to achieve the objective wilt not result In a level of environmental damage or public health risk which is substantially higher than that which now exIsts. Short term problems, In the form of elevated water and air concentrations and Increased fish contamination as a result of the disturbance of highly contaminated sediments, are a distinct possibility. The project expenditures in the case of failure will not be a total loss since valuable information regarding the cleanup of contaminated waterways will be obtained. 9-28 ------- Time Required to Achieve Cleanup/Isolation: Writing and reviewing technical specifications, bidding, making contractual arrangements, and obtaining all necessary permits will take a minimum of one year. During this time resampling and wetland analysis can take place. Actual dredging operations will take two seasons. The completion of the project can therefore take place within a minimum of three years. Ability to Meet Public Health and Environmental Criteria: The rationale behind the 40—hot—spot dredging program assumes that river bed contributions to water, biota, and air pollution are related to the sediment PCB concentration and that, all factors being equal, elimination of the areas of highest contamination will achiev a reduction in biouptake, desorption, resuspension, and volatilization of PCBs. It is reasonable to assume that PCB contributions to the water column by bottom sediments are heavily dependent on concentration. On a system—wide basis, however, the relative areal extent of highly contaminated sediments versus less contaminated areas should be considered. The areal extent of cold areas is nearly 17 times the total area of hot spots. The relative contributions of extensive cold areas with average PCB concentrations of 20 g/g should be weighed against the contribution of a relatively small area with an average concentration of 1.27 g/g. Moreover, when the contention is accepted that hot spots, by their nature, form in protected, low—velocity, low—turbulence areas; then It must also be accepted that scouring during high flows would be less for hot spots than for cold areas, and also that during low flows the dispersal of desorbed PCBs Is less because turbulent and diffusive transfer mechanisms are reduced. In the short term, removal of PCB hot spots may not reduce water oIumn concentrations, and hence PCB volatilization rates as dramatically as expected. In the long run, removal of hot spots will reduce the amount of PCBs in the river and possibly the time of exposure of the environment to PCB contamination. Removal of PCB hot spots could reduce fish contamination. Much of the microfauna and small fish biomass on which the larger species feed Is produced in shallow, protected areas, many of which are highly PCB—contaminated. Removal of these areas would substantially reduce the potential for biouptake and 9—29 ------- accumulation. Removal of only hot spots ‘would ensure that not alt of this critical habitat would be destroyed. Simplified food—web modeling by consultants of NYSDEC revealed that the Upper Hudson hot—spot dredging could possibly reduce fish PCB body burdens by 50 per- cent. Unfortunately this still leaves an average PCB concentration of 20—40 ppm, and It Is estimated that fish concentrations may not reach acceptable levels in less than a decade unless the ambient water concentration is reduced to 0.01 ppb. A strong connection between hot spot removal and the recovery of the fishery. however, has never been made. Degree of Cleanup/Isolation Achievable: The hot—spot dredging program wilt attempt to recover 1,453,000 cu yds of sediment contaminated with 170,000 pounds of the 290,000 pounds of PCB estimated to be in the Upper Hudson River bottom sediments. Factors detrimental to the achievement of this goal include: • Sediment losses to the dredge plume. • PCB—contaminated sediments missed by the bucket or dredgehead. • Accidental spills and pipeline breaks. • Hot—spot movement. • Accuracy of hot—spot delineations. Inaccuracies in dredge cut positioning and depth control, sediment sloughing, and difficulties with obstructions and debris will cause any dredging project to be less than 100 percent effective in retrieving all of the desired material. In addition, the operations themselves generate plumes of suspended material, most of which may never by recovered. A review of common dredging practices in relation to the recovery of contaminated sediments revealed that during normal operations, efficiencies may 9—30 ------- be as low as 65 percent. On the other hand, implementation of double—pass dredging to obtain the remaining contamination yields a substantial amount of uncontaminated sediment which must be treated as hazardous material. Tofflemire concluded by recommending the consideration of preplanned overlaps and dredge cuts controlled with the aid of modern electronic locating equipment. In another study, Tofflemire reported that conventional dredges in the Hudson River often created a highI PCB—contaminated surface scum. This scum could be contained with a floating boom positioned downstream from the dredge. Malcolm Pirnie, Inc., estimated that unrecovered sediment resulting from these loss mechanisms would total about six percent of the amount of material to be dredged when a depth of 36 Inches was specified. Assuming that the percentage of PCBs missed or lost during the dredging operation is equal to the percentage of sediment missed or lost, approximately 10,000 pounds of the estimated 170,000 pounds of PCBs residing in hot spots will not be recovered. The amount of PCBs missed or lost during the dredging operation can be minimized if the mitigating measures which have already been specified are followed. In addition, a comprehensive monitoring plan will be Implemented which will require an immediate cessation of dredging activities if specific water quality criteria indicate excessive tosses. Accidental spills and pipe breaks are distinct possibilities. Such losses could be minimized by requiring t e immediate halt to activities If such an event occurs. In addition, incentives for secure operating procedures will be offered. The effectiveness of the 40—hot—spot dredging program will depend heavily on the degree of scour and amount of movement which has occurred in the river since the initial survey was completed in 1978. According to estimates presented earlier in this, report, approximately 25,000 pounds of PCBs have been transported over the Federal Dam at Troy. Assuming that the locations of hot spots have not changed substantially and that the transported PCBs originated from turbulent, high— velocity “cold areaS,” then the maximum amount of PCBs which could be removed 9—31 ------- (with dredge losses at 6 percent) is about 160,000 pounds, or 55 percent of the total PCB burden of the sediments in the Upper Hudson River. If, on the other hand, the 25,000 pounds of transported PCBs came from the hot spots, then the maximum amount which could be recovered would be 136,000 pounds. This is still 47 percent of the total PCB burden. The accuracy of hot—spot delineation Is an unknown quantity which may substantially influence the effectiveness of the dredging alternative. The ratio of low—to—high PCB analysis results for duplicate samples is at least 3 to 1. ThIs fact casts some doubt about the quality of the data with which hot spots were mapped. The variability of PCB concentration in the sediment itself is extremely high. It is suspected that because low PCB values are often found: very close to high concentration values, hot deposits are actually very localized phenomena. It is possible that many more small areas of high PCB concentrations may exist which were never detected. It Is also possible that much of the material in designated hot spots need not be removed. Ability to Meet Legal and Institutional Requirements If contaminated sediments exceeding 50 ppm of PCB concentrations are removed, they are subject to the regulations and standards under TSCA (Toxic Substances Control Act). In addition, a permit authorized under Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act would be required. State permits would be required for the dredging and transport of contaminated sediments and for the disturbance of wetlands. Ability to Minimize Community Impacts: Excessive noise during the dredging process Is a possible adverse community Impact. The State estimated that residents within a radius of 1600 feet may experience annoying levels of noise, especially at night. The population density along the project area, however, is low, and dredging should not extend beyond several weeks in any one location. Furthermore, noise levels will be minimized by equipment maintenance and by mufflers. 9—32 ------- Removal of PCB—contaminated sediments will cause an adverse community impact in the form of anxiety about PCB volatilization, contaminated cash crops, lower market values for adjacent properties, and general inconvenience. This problem was made clear in the lawsuit against NYSDEC. This lawsuit seeks to overturn the state’s decision to grant siting and operating permits. It is likely that many of these fears will not be quieted by scientific reasoning and that the final outcome will be decided by litigation. Therefore the ability of the project to minimize community impacts is low. Commercial Impacts: Dredging of 40 hot spots in the Upper Hudson River will Improve the rate of recovery of the fishery, but the time it will take before the fish population becomes suitable for use is unknown. In th short term, dredging equipment may interfere with river traffic; however, the future use of the river for transportation and hydroelectric power would be assured. Therefore, the effects of the 40—hot—spot program on the commercial environment is favorable. Costs: Detailed costs were estimated and are included in Appendix C. 9.3.1.6 Remedial Alternative: Reduced—Scale Dredging DescriptIon: The original 40—hot—spot dredging program was rescoped, and substantial changes were made to increase the cost—effectiveness of the dredging alternative. Cost analyses by Malcolm Pimie, Inc., have shown that the costs of dredging, transport, and treatment of the sediments in the 20 hot spots of the Thompson Island pool are the lowest of any other pool in the Upper Hudson River. Dredging of Thompson Island Dam pool hot spots is advantageous for a number of reasons; these deposits have, with few exceptions, the highest PCB concentrations per unit area when compared to other hot spots. Studies have also shown that hot spots in this reach are the most susceptible to scour. Only one hot spot (number 18) Is associated, with a major wetland. Finally, If the proposed containment site is approved, transportation difficulties will be minimized by the close proximity of the site. 9—33 ------- The reduced—scale dredging program will proceed along the lines outlined by Malcolm Pirnie, Inc., for the 40—hot—spot dredging program. Sampling and wetland analysis will take place during the first year before dredging. Both hydraulic and clamshell dredging systems, similar to those outlined above, will be used to dredge the hot spots in the second season. If the program is highly successful, information and experience gained can be used to evaluate the cost—effectiveness of dredging hot spots in lower reaches. Applicabillty: The reduced—scale project is applicable to bottom sediments between the Thompson Island Dam and Rogers Island. Technology Status: Applicable dredging technology has already been reviewed and shown to be suitable for recovering contaminated sediments. Essentially no dredging process design changes are required for the reduced—scale project. Risk and Effect of Failure: The reduced—scale project does not introduce additional risks beyond those of the original 40—hot—spot program. In fact, the reduced—scale project will have less of a conflict with wetland destruction than the original plan. The effects of failure, in terms of cost, will be reduced because of the lower expenditures. Time Required to Achieve Cleanup/Isolation: As in the original project, probing and sampling the sediments will taka approximately one year. The dredging of the Thompson Is ’Iand pool will require one season. Therefore, the cleanup and isolation of the desired material will take less than two years to accomplish. Ability to Meet Public Health and Environmental Criteria: As with the full scale project, the relative contribution to PCB buildup of the hot spots, compared to the contribution of cold areas, should be evaluated. However, the reduced—scale project will attempt to clean up a relatively larger area for the amount of money expended. Therefore, even though the degree of environmental cleanup may be 9—34 ------- less for the reduced—scale project, the amount of improvement per dollar expended should be greater than for the full—scale project. Degree of Cleanup/Isolation A’chi&iable: Dredging of the Thompson Island pool will attempt to remove 645,000 Cu yds of material and 106,000 pounds of PC8s. Assuming a 6 percent loss of material, which is proportional to the amount of PCBs missed or lost, the maximum amount of PCBs which could be removed is 99,000 pounds, or 35 percent of the total PCB burden of Upper Hudson River bottom sediments. Movement and scour of hot spots in the Thompson Island Dam Pool Is liable to be much more severe than In other pools. If hot—spot dispersal- has occurred, it may not be desirable to implement the reduced—scale project unless new hot spots have been formed and can be located. A limited sampling program designed to detect changes in hot spots has recently been completed. Analysis of the data showed that some hot spots may have moved while others did not, confirming the need for sampling if any in—river remediation Is taken (see Appendix E). In light of the possible changes in hot spots in the Thompson Island pool, it might be desirable to consider the dredging of hot spot number 34 in the lock 5 pool. This is a massive deposition area which is located at the mouth of lock 6. It is possible that if substantial scouring has occurred in the Thompson I iand pool, much of the transported material may have settled in that area. Ability to Meet Legal and Institutional Requirements: If contaminated sediments exceeding 50 ppm of PCB concentrations are removed, they are subject to the controls under TSCA (Toxic Substances Control Act). In addition, a permit authorized under Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act would be required. State permits would be required for the dredging and transport of contaminated sediments and for the disturbance of wetlands. Ability to Minimize Community Impacts: Reduction in the amount of sediment to be removed is expected to reduce those community concerns that were outlined in 9—35 ------- the 40—hot—spot alternative. Therefore the ability to minimize community impacts is only moderate to low. Commercial Impacts: Dredging in one pool will not require any barge traffic through the lock system; therefore, the impact of the reduced—scale project on commercial shipping may be lower than for the 40—hot—spot project. It is believed that most of the PCB—contaminated material which moves into the estuary originates from the Thompson Island Dam pool. Cleanup of sediment in this area, if the expected amount of material can be recovered, should have the same effect on the lower Hudson River fishery as the 40—hot—spot program. The dredging of the 20 Thompson island pool hot spots, however, may not substantially improve the recreational fishery in the Upper Hudson below the Thompson Island Dam. Costs: Detailed costs were estimated and are included in Appendix C. 9.3.1.7 Remedial Alternative: No—Action for River Sediments, Routine Dredging Continues, Water Supply is Not Treated Description: Routine channel—maintenance dredging would remove approximately 5,000 lbs of PCBs per year over the next 10 years or about 15 percent of the estimated Hudson River PCBs according to estimates in the DEIS. No other action Will be taken with respect to the contaminated sediments. AØplicability: Routine channel dredging Is necessary for navigational purposes. Technology Status: The technology for dredging currently exists; routine dredging is currently performed. Risk and Effect of Failure: No PCBs are being removed under this alternative except those PCBs removed by routine dredging. The possible impacts of this alternative are reviewed in Chapter 5. 9—36 ------- Time Required to Achieve Cleanup/Isolation: None Ability to Meet Public Health and Environmental Criteria: The concerns expressed in Chapter 5 will still exist. Natural mechanisms will predominate in the reduction of PCB levels. Fish—flesh PCB levels will remain elevated, and monitoring of PCB levels in air, drinking water, and fish flesh will have to be maintained. Degree of Cleanup/Isolation Achievable: None. AbilIty to Meet Legal and Institutional Requirements: None needed. Ability to Minimize Community Impacts: Short—term, construction—related effects would be avoided. Long—term effects due to concern about the presence of the contamination in the river would continue. Commercial Impacts: Commercial and recreational fisheries of the Hudson River would still be threatened. A potential impact of increased contamination of the Lower Hudson River sediments would require routine monitoring. Costs: Detailed costs were estimated and are included In Appendix C. 9.3.1.8 RemedIal Alternative: No Action for River Sediments, Routine Dredging Continues, Water Supply is Treated Description: Routine channel maintenance dredging would remove approximately 5000 pounds of PCBs per year over the next 10 years or about 15 percent of the estimated Hudson River PCBs. Water treatment can reduce PCB content in drinking water by 40—80 percent using granular activated carbon filtration, reducing PCB levels from the present approximate level of 0.02 ppb to an undetectable level. Applicability: Granular activated carbon filtration is applicable to removal of PqBs from potable water supplies; this method is currently being used. Technology Status: The technologies currently exist and are well established. 9—37 ------- Risk and Effect of Failure: Failure of the granular activated carbon filtration would result in higher PCB concentration in water for human consumption. Concentrations would be expected to increase to the present level of about 0.02 ppm. Time Required to Achieve Cleanup/Isolation: The total time required would depend on the time required to design and bid the water—supply granular—activated-- carbon filtration system. This aiternative could be implemented within one month. Ability to Meet Public Health and Environmental Criteria: Under this alternative. exposure to PCBS could still occur by: • Ingestion of contaminated fish and aquatic life • inhalatIon of PCBs absorbed onto particulate matter • Dermal and possible oral exposure through use of the Hudson River for recreational purposes • Ingestion of terrestrial wildlife feeding on contaminated materials Monitoring of air and fish flesh will be required on a continuing basis. Degree of Cleanup/isolation Achievable: This alternative will virtually eiiminate PCBs in the potable water system at Waterford. it will not affect the PCBs in the river. Ability to Meet Legal and Institutional Requirements: No permits would be required. Ability to Minimize Community Impacts: Short—term, construction—related effects would be avoided. Long—term effects due to concern about the existence of the PCBs in the river will continue to exist. 9-38 ------- Commercial Impacts: Commercial and recreational fisheries of the Hudson River would still be adversely affected. Because of the potential for increased contamination of sediments in the Lower Hudson River, routine monitoring would be required. Costs: Detailed costs were estimated and are included in Appendix C. 9.3.1.9 Remedial Alternative: Total Removal of all Remnant Deposits Description: Total removal of the remnant deposits would entail movement of 370,000 cubic yards of contaminated material containing some 49,000 lb of PCBs. This alternative would include removal of materials .with low levels of contamination. The contaminated material would have to be disposed of by hauling to a secure containment site or by detoxification or incineration. This alternative would involve an extensive amount of sampling for PCBs on exposed sediment banks above the former Fort Edward Dam to ensure that all contaminated sediments were removed. ApplicabIlity: Total excavation of the remnant sites is applicable to all material which contains PCBs upstream from the former Fort Edward Dam. This would include, but not be limited to, the five previously defined remnant deposits. Technology Status: Complete excavation and removal of contaminated soils is a proven technique for remedlation of uncontrolled hazardous materials. Risk and Effect of Failure: Failure could occur due to missed small PCB deposits, from contaminated areas formed during hauling, from contamination at the containment site,, or from incomplete disposal methods. The impacts of these failures would be minimal because they should be very small in scale. Time Required to Achieve Cleanup/Isolation: This alternative would require the clearing, grubbing, and construction of haul roads; excavation, hauling, and disposal of contaminated sediments; and regrading and revegetation of the disturbed areas. Assuming that construction proceeds simultaneously at all five remnant deposit 9—39 ------- sites, the construction phase would probably require two construction seasons to complete. This period does not include the completion of a containment site which may or may not be constructed concurrently. Ability to Meet Public Health and Environmental Criteria: Total removal of the remnant deposits may lead to slight decreases in the PCB contamination levels in the Hudson River. It wilt reduce the possibility that humans could be directly exposed to contaminants by walking on the site. Degree of Cleanup/Isolation Achievable: Complete cleanup of the contaminated material in the remnant deposits is possible through this alternative. Ability to Meet Legal and Institutional Requirements: Regulations under TSCA will be applicable to the removal of sediments with PCB concentrations greater than 50 ppm. A State permit would be required for the transport of contaminated material from the remnant deposit Sites. Local permits might also be required. Ability to Minimize Community Impacts: If implemented, this alternative would have separate effects during construction and after construction. During construction, if disposal of the hazardous material involves trucking, there may be impacts on traffic, roads, air pollution levels, noise levels, and the employment in the surrounding communities. Employment opportunities may increase regardless of the alternative chosen; however, the alternative with the largest quantity of work will provide the most stimulation of the local economy. Other post— construction impacts include rise in property values and higher health standards: Commercial Impacts: Impacts on the commercial Industry should be positive. Future construction along the river below Glens Fall would be more likely because the threat and notoriety of PCBs would be reduced. Costs: Detailed costs were estimated and are included in Appendix C. 9—40 ------- 9.3.1.10 Remedial Alternative: Partial Removal of Remnant Deposits Description: With an assumed cut—off point of 50 ppm for PCB concentratIon, partial removal of the remnant deposits will entail removal of material from deposits 3 and 5. Deposit 3a has previously been removed, while deposits 1, 2, and 4 have an average PCB concentration of below 50 ppm throughout the deposits and would not require removal. Applicability: This alternative is applicable to remnant sites 3 and 5, since they meet the assumed requirements of PCB concentrations higher than 50 ppm. If the 50 ppm requirement is changed for any reason, the sampling information must be reviewed. Technology Status: The partial removal of the remnant deposits would have a high technology rating according to state—of—the—art procedures. This alternative leads to complete or nearly complete removal of PCBs above 50 ppm within the remnant deposits. Risk and Effect of Failure: If proper construction and safety techniques are followed,-there Is a very small risk of PCBs entering the environment from deposits 3 and 5. Problems could occur from exposed PCBs at the remaining deposits and from PCB remaining at deposits 3 and 5, but the low concentrations in these areas make It unlikely that they will be serious. Time Required to Achieve Cleanup/Isolation: In order to excavate, haul, and dispose of the sediments, and to regrade and revegetate the disturbed areas, one construction season would be required, assuming that operations would proceed simultaneously at both remnant deposit sites. Ability to Meet Public Health and Environmental Criteria: Partial removal of the remnant deposits will prevent public contact with highly contaminated soils. Although deposits 1, 2, and 4 will not be removed, their relatively low PCB 9—41 ------- concentrations pose decreased public and environmental threats. One concern Is the increased air and (to a lesser degree) water contamination by PCBs due to direct handling of the contaminated material during construction, and potential spills during transport. This should be a short—term environmental effect. Degree of Cleanup/Isolation Achievable: If the results of the testing program are updated sufficiently to allow for correct estimates of PCB concentrations versus depth, this alternative should eliminate high—level PCB concentrations in the remnant deposits. It will not eliminate public access to remnant areas with less than 50 ppm PCBs. Ability to Meet Legal and Institutional Requirements: Regulations under TSCA will be applicable to the removal of sediments with PCB concentrations greater than 50 ppm. A State permit would be required for the transport of contaminated material from the remnant deposit sites. Local permits may also be required. Ability to Minimize Community Impacts: Community impacts will result from the truck traffic while contaminated material is removed and topsoil replaced. Leaving some sites untouched may cause concern among the residents in the areas. Costs: Detailed costs were estimated and are Included In Appendix C. -9.3.1.1 1 Remedial Alternative: Restricted Access to Remnant Deposits Description: Under this alternative, measures would be taken to deter access of people, vehicles, and wildlife to remnant deposits. The measures would Include: • Fencing of landward edge of all remedial areas • Seeding of remnant sites Applicability: This is applicable to remnant sites with concentrations of PCBs or other hazardous waste materials, and to general cases of restriction from public contact. 9—42 ------- Technology Status: Restricted access methods are proven, well—established methods. They are easily implemented in a situation similar to this, but in the same manner they are easily removed through such acts as vandalism. Risk and Effect of Failure: A relatively low—to—medium probability of failure is associated with these measures. Problems may arise from human ignorance or error, such as ignoring warning signs or incorrect construction techniques. The probability of these types of problems is highly variable. Time Required to Achieve Cleanup/Isolation: One construction season will be required to install the fences and signs and to seed the remnant deposits. Ability to Meet Public Health and Environmental Criteria: Restricting access to the remnant deposits does curb public contact with PCBs, but does not affect PCB movement Into the environment: Degree of Cleanup/Isolation Achievable: This alternative will provide only minimal isolation. Ability to Meet Legal and Institutional Requirements: No requirements are expected with the possible exception of local permits. Ability to Minimize Community Impacts: Community impacts from construction would be low due to the ease of construction for the alternative; however, the impacts would be high due to concerns resulting from the PCBs remaining. Commercial Impacts: Commercial impacts will be very low from this alternative. Costs: Detailed costs were estimated and are included in Appendix C. 9—43 ------- 9.3.1.12 RemedIal Alternative: In—Place Containment of Remnant Deposits Description: This alternative entails the placement of a 2—foot—thick layer of soil over the existing remnant deposits, seeding the soil, and protecting the associated river banks with riprap. Remnant deposits 3 and 5 have previously been regraded and rlprapped so this action will be required at deposits 2 and 4 only. Applicability: This alternative is applicable to the remnant sites upstream from the former Fort Edward Dam. Remnant deposit 3a has already been removed, thereby eliminating it. The exact extent of the deposits will have to be determined in the field during Remedial Investigation to assure complete containment of the hazardous material. Technology Status: Use of an Impermeable cover and bank reinforcement to contain hazardous wastes has proven adequate In the past. Proper equipment and procedures must be maintained during placement of the cover, while bank reinforcement material must be properly placed and sized to prevent scour and erosion. Risk and Effect of Failure: A relatively low probability of failure exists If proper engineering and construction techniques are followed. PCB—contaminated material may enter the environment through groundwater movement beneath the proposed cap; however, the likelihood of contamination spreading would be decreased if a soil cover were emplaced. Time Required to Achieve Cleanup/Isolation: This alternative would require the clearing, grubbing, .and construction of haul roads; development of a borrow site; excavation, hauling, and placement of topsoil, subsoil, and riprap; and revegetation of the remnant deposit areas. Approximately two construction seasons may be required for the simultaneous containment of all five deposits Ability to Meet Public Health and Environmental Criteria: In—place containment of the existing remnant deposits will reduce PCB losses into the environment. This 9-44 ------- alternative is also beneficial from an environmental standpoint since contaminated sediments should not be stirred up during construction. Degree of Cleanup/Isolation Achievable: This alternative will prevent public contact with the PCB—contaminated remnant material. It will not prevent the such material from entering the environment. Ability to Meet Legal and Institutional Requirements: Federal permitting may be applicable under RCRA. State construction permit(s) may also be required for the placement of soil cover. Local permits may be applicable as well. Ability to Minimize Community Impacts: This alternative will minimize - community impacts. Traffic noise and pollution will last only during construction. Commercial Impacts: Covering the remnant areas will have minimal commercial impact. PCB entry Into the river will be reduced, thus reducing the threat of increased contamination in the lower estuary. Costs: Detailed costs were estimated and are included in Appendix C. 9.3.1.13 Remedial Alternative: In— Situ Detoxification of Remnant Deposits By Use of KOHPEG System Description: Potassium hydroxide (KOH) and polyethylene glycols (PEG react with and destroy polychlorlnated biphenyls (PCBs), producing reaction products of aryl polyglycols and biphenyls. The presence or absence of air apparently has little effect on the reaction. Reaction time is reduced with increased temperatures; however, the reaction will proceed under ambient conditions. KOHPEG has not been applied In the field to soils containing PCBs, but application to remnant sites conceptually might proceed as follows. KOHPEG could be sprayed on the remnant site, followed by rototilling. The amount of reagent to be applied 9—45 ------- would be equal to 6 percent of the weight of remnant deposits being treated. This weight could be determined initially by assuming a depth of treatment, perhaps 12 inches. The best time for applying the reagent would be late spring in order for the reaction to have the benefit of the warm temperatures during a full summer. The following year. testing could be done to establish the level at which PCBs have been destroyed, and that layer of decontaminated remnants could be removed for disposal. This sequence of operations could be repeated until the full depth of the remnant deposits had been decontaminated. Adjustments in the application rate and the frequency of rototilling (or perhaps even deleting rototilling) on subsequent applications could be made, based on the results obtained from the previous application. Applicabiilty: The in—situ detoxification of remnant deposits could be applicable to all five remnant deposit areas, if it were to be used. Technology Status: The KOHPEG system is still .in the laboratory stage, where work has been done on PCBs contained in transformer oils, sands, and soils. The use of KOHPEG to destroy PCBs contained in soils seems to show promise. While PCBs contained in sand have been destroyed In the laboratory in a few days, PCBs in soils containing significant organics take significantly longer, perhaps several months. A field application test is expected to begin in the summer of 1984, and a projection is that 12 to 18 months will be required for development of techniques for large—scale application. Additional research is required to establish dilution ratios for the reagent dosage rates, and methods of application, as well as to develop procedures that will assure contact of the reagent with the contained PCBs. Risk and Effect of Failure: The probability of failure of KOHPEG is dependent upon the degree to which the solution comes in contact with the PCBs. Providing sufficient contact is made for the required period of time, virtually all PCBs will be destroyed. In the event of failure, however, the PCBs may possibly become 9—46 ------- exposed to the atmosphere and to the general public, or may be transported into the river through erosion. Time Required to Achieve Cleanup/Isolation: It may take several months for the reagent to destroy the contained PCBs, and the speed of the reaction increases with increasing temperatures. It would follow that it will likely require at least one summer season for destruction of PCBs after the reagent is applied. The time to treat all remnant areas to full depth of contamination will depend upon the availability of adequate quantities of reagent and upon the manpower commitment to treat several areas concurrently. It is not possible at this time to predict the total elapsed time. Ability to Meet Public Health and Environmental Criteria: Acute toxicity tests have been performed on the reaction products from the destruction of PCBs in transformer oils, and they were found to have no biological activity other than being a mild eye irritant. No long—term biological tests have been performed. Polyethylene glycols in the laboratory have been degraded by anaerobic bacteria. It is expected that reaction products will be biodegradable since they contain oxygen. Analyses of transformer oil and the reaction products after treatment of PCB—contaminated transformer oil revealed no evidence of PCBs, polychiorinated dlbenzofurans (PCDF), or polychlorodibenzodioxins (dioxins). Degree of Cleanup/Isolation Achievable: Assuming that the KOHPEG mixture comes in contact with all PCBs present, essentially 100 percent cleanup is achievable. Ability to Meet Legal and Institutional Requirements: No requirements are expected. Ability to Minimize Community Impacts: This process will minimize community Impacts if no digging of the contaminated remnants is required for the reagent to contact all contained PCBs. There may be some volatilization of PCBs during rototilling, but it should be .minimal. No transport or treatment off site would be required. 9—47 ------- Commercial impacts: The commercial Impacts resulting from the implementation of this alternative will be minimal. Costs: Detailed costs were estimated and are Included in Appendix C. 9.3.1.14 Remedial Alternative: No—Action on Remnant Deposits with Restricted Access to Deposits 3 and 5 . Description: This alternative entails no action on remnant deposits 1, 2, and 4; and restricting access to deposits 3 and 5. Under this assumption, remnant deposits 3 and 5 will require fencing, warning signs, and reseeding. Applicability; The restricted—access portion of this alternative is applicable to remnant deposits 3 and 5. while no action will be taken on deposits 1, 2 and 4. Technology Status: There Is no technology status involved with the no—action portion of this alternative. The restricted—access portion of the alternative is a well established method. It can be easily Implemented for deposits such as those encountered behind the former Fort Edward Dam. Risk and Effect of Failure: The no—action portion would not appreciably remove or decrease the current PCB concentrations In the environment. Concentrations of PCBs would decrease slowly and it would be many years before the PCBs would finally be flushed from the system. Restricted access to remnant deposits 3 and 5 would have a low to medium probability of failure. Problems may arise due to human Ignorance, error, or vandalism. Major flooding would also cause problems, such as scour and destruction of the chain—link fence and of warning signs. This destruction process would allow the public to be in direct contact with the PCBs. Time Required to Achieve Cleanup/Isolation: Isolation could easily be achieved n a matter of one construction season. 9—48 ------- Ability to Meet Public Health and Environmental Criteria: With no action performed at remnant sites 1, 2, and 4. there will be no restrictions on the availability of PCBs to the environment. Restricting access to remnant deposits 3 and 5 does curb public contact with the PCBs, but does not allow for decreasing stream concentrations of the substance. As stated in the Risk and Effect of Failure section. scour allows for direct contact of PCBs with the environment. In addition the levels of PCBs will not be significantly reduced In the Hudson River and PCBs can still leach from the remnant areas. Degree of Cleanup/Isolation Achievable: Since 17.3 out of 5 acres of the remnant deposits will have restricted access, approximately 35 percent of the hazardous materials will be eliminated from direct contact with the public. There will be very little reduction of PCBs in the water system since all of the areas are still uncovered and rainwater can Infiltrate the contaminated sediments, washing them into the groundwater system and eventually into the Hudson River. It is therefore assumed that a minimal Isolation of the PCBs will be achieved. AbilIty to Meet Legal and Institutional Requirements: No requirements are expected with the possible exception of local permits. Ability to Minimize Community Impacts: Since minimal isolation of PCBs from the environment occurs, there would be a large number of community impacts. It is possible that property values will decrease and Individual stress levels increase. If implemented, this alternative would have a noticeable impact on the community. Commercial Impacts: Impact on the recreational and fishing Industries would cause continued losses. Commercial impacts would not be signflcantly reduced by this alternative. Costs: Detailed costs were estimated and are included in Appendix C. 9—49 ------- 9.3.1.15 Remedial Alternative: Partial Remnant Deposit Removal/Partial In—Place Containment Description: Under this alternative, remnant deposits 3 and 5 (deposits with PCB concentrations greater than 50 ppm) would be excavated and removed from the site. The remaining deposits would be contained in—place with a soil cover layer and reseeded. Applicability: This alternative Is suitable for all existing remnant deposit areas. As previously mentioned, sediments with PCB concentrations of greater than 50 ppm would be removed, and the remaining contaminated sediments would be contained in place. Technology Status: Excavation and removal of contaminated soils or sediment is a well established and widely used technology. Surface capping Is also a widely utilized construction technique, commonly used for isolation of hazardous wastes in landfills. The overall technology status rating is consequently very high. Risk and Effect of Failure: Essentially no failure risk is present for removal of contaminated deposits. Proper engineering/construction techniques must be followed to ensure satisfactory performance of a soil cap. There Is Increased potential for surface water infiltratIon if the cap is improperly installed or maintained, and a corresponding release of PCBs to the environment may result. Overall, the risk and effect of failure could be low to moderate. Time Required to Achieve Cleanup/isolation: It is expected that two construction seasons may be required to complete both simultaneous removal of remnant deposits 3 and 5 and simultaneous containment of deposits 1, 2 and 4. Ability to Meet Public Health and Environmental Criteria: A combination of removal and in—place containment will largely eliminate the release of PCBs into the environment. Air transport should be greatly reduced by the covering of the remaining deposits. Surface infiltration will be negated, and development of leachate in groundwaters would be minimized. 9—50 ------- Degree of Cleanup/Isolation Achievable: Assuming proper construction/placement of the protective coverings, nearly 100 percent of the PCBs in the remnant deposits will be isolated or removed from the environment. Ability to Meet Legal Institutional Requirements: Requirements under TSCA will be applicable to the removal of sediments with PCB concentrations greater than 50 ppm. State permits might be required for the transport of contaminated material and placement of the soil covers. Local permits may apply. AbilIty to Minimize Community Impacts: This alternative will result in low to moderate impacts on the community. It can be expected that traffic congestion and noise will be present at moderate levels during the construction phase. Additionally, it is likely that some pubIic concern about potential health risks may arise since not all of the contaminated material will be removed from the vicinity. There is a possibility of spills during transport and of dust dissemination during excavation activities. Commercial Impacts: No negative commercial impacts are expected as a result of this alternative. There will be a decreased threat of high PCB levels in navigational dredge spoils requiring secure containment sites for disposal (with a resultant increase in navigation costs). A commercial fishery in the Hudson can be reestablished more quickly than if no remedial action Is taken as a result of this option. Costs: Detailed costs were estimated and are included in Appendix C. 9.3.1.16 Remedial Alternative: Partial Remnant Deposit Removal/Partial Restricted Access Description: This alternative involves the removal of remnant deposits 3 and 5, which have PCB concentrations above 50 ppm, and restricted access to all remaining contaminated sediments. Access would be restricted by means of fences 9—51 ------- on the landward sides of the deposits and by placement of warning signs on-all sides of the deposits. Additionally, the surfaces of all deposits would be reseedea to induce the establishment of turf. Applicability: This alternative is applicable to all existing remnant deposit sites. Only the deposit portions with average PCB concentrations above 50 ppm will be removed. Access will be restricted from the remaining contaminated areas. Technology Status: Both excavation and access restriction techniques are well established and commonly used. The technology status is therefore very high. Risk and Effect of Failure: Contaminated sediment removal offers minimal “risk of failure. The restricted access methods previously discussed should be suffIcient to eliminate the potential for people or animals to come in contact with contaminated sediments. However, the access restriction methods do little to prevent surface water infiltration or high flow scour of the unremoved sediments. As a result, PCBs may be introduced into groundwater or reintroduced into the river system. Accordingly, the overall risk and effect of failure of the combined alternative is moderate. Time Required to Achieve Cleanup/Isolation: This alternative would require less than one construction season to restrict access to deposits 1, 2 and 4. However, removal of deposits 3 and 5 may require two construction seasons for completion, assuming that operations at both sites are conducted simultaneously: Ability to Meet Public Health and Environmental Criteria: Up to 88 percent of the total remnant—area PCB mass can be expected to be removed from the remnant deposit areas as a result of this alternative. The remaining contaminated sediments will be subject to surface infiltration, high flow scour, and volatilization. Since these areas constitute a small portion of the overall contamination, the environmental effects should be minimal. Additionaily, the restricted access should negate any public contact with the remaining sediments. 9—52 ------- Degree of Cleanup/Isolation Achievable: The removal of a large portion of the highly contaminated sediments is proposed. Access by people, animals, and vehicles would be minimized from the remaining contaminated sediments, but scour during high river flows and surface water infiltration into the contaminated sediments would not be controlled in these areas. On the whole, the degree of isolation achievable would still be high since a very large percentage of the PCB mass would be removed from the immediate environment. AbilIty to Meet Legal and Institutional Requirements: Regulations under TSCA will be applicable to the removal of sediments with PCB concentrations greater than 50 ppm. A State permit may be required for the transport of contaminated material; local permits may also be applicable. Ability to Minimize Community Impacts: During the excavation/construction phase of this alternative both noise and traffic congestion are likely to be present to a moderate degree. Public concern is likely since not all of the contaminated sediments will be removed, and the signs and fences will be a constant visual reminder of the presence of hazardous materials in the community. Dust created during excavation and spills during transport could adversely affect the community. Commercial Impacts: No negative commercial impacts are expected as a result of this alternative. Beneficial impacts could result in that there would be a lower risk of having to deposit dredge spoils In a secure landfill, and quicker reestablishment of the commercial fishery in the river. Costs: Detailed costs were estimated and are included In Appendix C. 9.3.1.17 Remedial Alternative: Partial Remnant Deposit In—Place Containment/PartIal Restricted Access Description: Under this alternative, access will be restricted from remnant deposits 1, 2, and 4, which contain PCBs in concentrations less than 50 ppm, by chain—link fencing and by warning signs. Remnant deposits 3 and 5 have PCB concentrations in excess of 50 ppm and will be covered by a soil-layer and seeded. 9—53 ------- Applicability: This combination of alternatives Is applicable to the remnant deposits to control the transport of PCBs into the environment. Technology Status: In terms of state—of—the—art solutions, restricting access and in—place containment of hazardous waste deposits have proven to be a successful approach. Although complete removal or total containment would prove to be more effective In eliminating future PCB contamination, this alternatIve has a relatlv&y high technology status. Risk and Effect of Failure: The risk of failure associated with the restricted access to deposits 1, 2, and 4 Is high simply because PCBs are still able to come in contact with the environment. Conversely the risk of failure for deposits 3 and 5 would be relatively low, with only the removal alternatives providing a lower risk of failure. PCBs from deposits 3 and 5 would be able to enter the environment if scouring of the impermeable cap occurred as would PCBs from groundwater movement. Time Required to Achieve Cleanup/isolation: It is expected that both the containment of remnant deposits 3 and 5 and access restriction to the other deposits can be completed in one construction season if deposits 3 and 5 are covered simultaneously. Ability to Meet Public Health and Environmental Criteria: The combination of restricted access and In—place containment will result in various public health and environmental eftects. Restricting access only prevents direct contact with PCBs by the public. The problems of water and air pollution will not be solved. Selection of this remedial measure will leave the fishing and recreational activities with their current restrIctIons. Degree of Cleanup/Isolation Achievable: This particular combination of alternatives will achieve Isolation from the environment at deposits 3 and 5, and very little isolation at deposits 1, 2, and 4. Thus 41,000 out of the 47,000 lbs will be isolated, or 88 percent of the PCBs contained in the five remnant deposits. 9-54 ------- Ability to Meet Legal and Institutional Requirements: State construction permit(s) may be applicable for the placement of the soil cover. Local permits may also be applicable. Ability to Minimize Community Impacts: Reduction of community impacts from high—level PCB concentrations will be achieved. PCBs from deposits 1, 2. and 4 will be able to enter the environment at the same rate as is presently being experienced. This situation may lead to decline In property values, health monitoring programs, and increased stress related to these impacts. It is also possible that due to scouring and groundwater movement, small concentrations of PCBs may enter the environment from areas 3 and 5, resultIng in the same effects previously mentioned. In all, even though the overall PCB availability is being decreased, there will still be PCBs entering the environment. Due to the large volume of material which has to be hauled to remnant deposits 3 and 5. traffic problems and roadway damage may occur. Commercial Impacts: This alternative results in a decrease in PCB movement from the remnant deposits; however, there is very little commercial impact overall. Costs: Detailed costs were estimated and are included in Appendix C. 9.3.1.18 Remedial Alternative: Partial Remnant Deposit In—Place ContaLnment/Partial In—Situ Detoxification Description: The combined alternative, in—place containment and in—situ detoxification, will be designed to detoxify those areas with greater than 50 ppm PCB concentrations (remnant areas 3 and 5) with KOHPEG and to contain or Isolate those areas with PCB concentrations less than the 50 ppm level (1, 2, and 4) with a soil cover layer. 1 his combination offers the advantage of detoxification of the most contaminated sediments and isolation of those sediments which are not governed by the Toxic 9—55 ------- Substances Control Act (TSCA). The recommended detoxification method Is the KOHPEO process and the recommended containment process is that described In Section 9.3.1.12. The final result is that all of the PCBs located in the remnant area will be either detoxified or stabilized and contained. Applicability: This combination alternative will be applicable to all of the remnant sites and will detoxify or contain all of the PCB’s. The detoxification process — KOHPEG — will be used on remnant areas 3 and. 5, while areas 1. 2. and 4 will undergo containment and stabilization measures. Technology Status: The technologies to be used for the containment of the remnant deposits are widely used methods for hazardous waste containment. If correct and accurate measures are taken to assure the integrity of the cover and bank reinforcement, there should be no problems with the PCB’s leaching or being scoured during periods of high river flows. The KOHPEG process is based on technology which is currently experimental in nature. This process is the best suited technology for the in—situ detoxification of remnant sediments. EPA is encouraged by this process and is optimistic about its results. Risk and Eftect of Failure: There is some risk associated with the in—place containment of remnant deposits because PCBs would not be removed from the river system. If a containment liner or erosion control measure were to fail, a PCB release would result. There is not enough information available at this time to determine what effect a release would have, although any release could be a cause for concern. The risk involved with the use of the KOHPEG process would entail knowing what by—products were formed as a result of the dechlorination process as well as what by—products may result from other contaminants located on site. An additional risk the process poses is that a contaminated source may still exist if 100 percent detoxification is not achieved (due to process or operational errors). 9—56 ------- Overall a low risk would result from decontamination of remnant areas 3 and 5, but the critical factor to consider is the status of the technology. Because the KOHPEG process is a laboratory—scale project. the process must be assigned a high risk factor (See Section 9.1.1.2). Time Required to Achieve Cleanup/Isolation: The in—place containment of remnant deposits 1, 2 and 4 should be completed in one construction season. However, it is likely that the detoxification process will require at least one summer season for destruction of PCBs after the reagent is applied, and it is not possible at this time to accurately predict the total elapsed time. Ability to Meet Public Health and Environmental Criteria:. Environmental and public health criteria can be met with adherence to a strict Quality Control and Quality Assurance program. If the actions are constructed as final designs indicate, no major releases of PCBs should result. The implementation of this alternative will not reduce the PCB levels already in the river system; it will reduce PCB releases from the remnant sites. In the past, scouring and erosion has removed contaminated sediments from these sites, adding PCBs to the environment. The level of reduction of PCB addition from scouring and erosion cannot be fully determined at this time. Degree of Cleanup/Isolation Achievable: Estimates of work done with the KOHPEG process shows that when used on contaminated soils or sediments, a 100 percent detoxificatIon of PCBs Is achievable. This process would be used to detoxify those sediments In areas 3 and 5. Remnant areas 1, 2, and 4 could effectively be 100 percent isolated from potential scouring or leaching. Ability to Meet Legal and Institutional Requirements: State construction permit(s) may be applicable for the placement of the soil cover. Local permits may also apply. 9—57 ------- AbIlity to Minimize Community Impacts: Community impacts should be moderate. While detoxification or covering of the remnant areas will reduce community concern in the long—term, anxiety may be increased due to the use of an experimental procedure. Increased traftic and noise will occur during implementation. Commercial Impacts: There are no foreseeable negative commercial Impacts associated with the Implementation of this project. Positive impacts would result from securing or destroying the PCBs. The commercial fishery on the Hudson may be reestablished in a somewhat shorter period of time, since some PCBs are being destroyed. Costs: Detailed costs were estimated and are included In Appendix C. 9.3.1.19 Remedial Alternative: Partial Removal of Remnant Deposits/Partial In—Situ Detoxification Description: This alternative entails the removal of materIal in remnant deposits 1, 2, and 4 and detoxifying deposits 3 and 5 with KOHPEG. The estimated volume of,matertal to be removed is 157,300 yd 3 , which leaves a volume of 192,600 yd 3 to be treated. The in—situ detoxification method to be considered is KOHPEG. which involves applying a mixture of potassium hydroxide• and polyethylene glycol to the contaminated materials and mixing with a rotary tiller. This process dechlorinates the PCBs, producing compounds which are either biodegradable or non— bloaccumulative. Applicability: The removal segment of this alternative applies to remnant deposits 1, 2, and 4, while the in—Situ detoxification segment will be applied to remnant deposits 3 and 5, which have the highest concentration of PCBs. Technology Status: The technology used for the removal of PCB—contaminated materials is well—accepted practice for hazardous waste disposal. when state—of— 9—58 ------- the—art procedures are used. The KOHPEG process has proved promising during the experimental stages, although it has not yet been used on a large—scale project. Risk and Effect of Failure: There is minimal risk involved with removing the contaminated materials from deposits 1, 2. and 4, provided that strict safety and construction techniques are utilized. Some volatilization of PCBs may occur during removal, but the effects of this disturbance should be minimal. A greater risk is involved with the KOHPEG method of detoxification, however, since it has not been demonstrated on a larger scale. Crucial to its success is the degree to which the detoxifying agents can be mixed with and come in contact with the PCBs. Time Required to Achieve Cleanup/Isolation: It Is expected that at least one construction season may be required to complete the simultaneous removal of remnant deposits 3 and 5. Detoxification of deposits 1. 2 and 4 would require at least two construction seasons. Ability to Meet Public Health and Environmental Criteria: The combined actions of removing and detoxifying the contaminated materials in the remnant deposits should virtually eliminate the presence of PCBs in these areas if performed correctly. Degree of Cleanup/Isolation Achievable: The removal and detoxification of the remnant deposits will be theoretically capable of eliminating all of the PCBs from these areas, provided strict quality control practices are followed during Implementation. Ability to Meet Legal and Institutional Requirements: A State permit may be required for the transport of contaminated material from the remnant deposit sites. Local permits may also be required. Ability to Minimize Community Impacts: Some impacts on the surrounding communities will be felt during the removal of contaminated materials and the 9—59 ------- application of KOHPEG. Truck traffic will have significant effects on the traffic patterns and road conditions In the community. Long—term effects will be beneficial due to the elimination of the PCBs. Commercial Impacts: Commercial impacts will be limited. Elimination of the PCBs will Improve chances of river edge construction above Fort Edwards. It will reduce the PCB Inventory in the Upper Hudson River, helping to speed up the PCB flush—out. Costs: Detailed Costs were estimated and are included in Appendix C. 9.3.1.20 Remedial Alternative: Partial In—Situ Detoxification of Remnant Deposits/Partial Restricted Access Description: This alternative involves detoxifying remnant deposits 3 and 5 (deposits having the highest PCB concentrations) and restricting access to those deposits which are not detoxified. The detoxification will be performed in situ using the KOHPEG method. Access to the remaining deposits will be restricted by chain—link fences on the Iandward sides of the remnant deposits and warning signs placed on all sides of the deposits. Applicability: Detoxification of the remnant deposits is applicable to deposits 3 and 5. where PCB concentrations are greatest, a volume of approximately 192,600 yd. 3 . Access to areas 1, 2, and 4 wIll be restricted to prevent people, animals, and vehicles from entering the areas. The total area to be restricted is approximately 32.5 acres. Technology Status: In—situ detoxification of PCBs using KOHPEG has been successful in the experimental stages; however, it has not yet been demonstrated on a larger scale. Restricting access to the deposit areas Is done with well— established methods which are easily implemented. Acts of vandalism, however, can easily destroy the components of this method and render the site insecure. 9—60 ------- Risk and Effect of Failure: The probability of failure of the KOHPEG method is dependent on the degree to which the detoxifying agents can come in contact with the PCBs. If all PCBs are not destroyed, they will adversely affect the public and the environment through volatilization, surface water/sediment transport, and groundwater and biota effects. A relatively low—to—medium probability of failure is associated with restricting access to the remnant deposit areas. Problems may arise due to incorrect construction techniques, human ignorance of the warning measures, and intrusion onto the sites by wild animals. The probability of these problems is highly variable. The risk assàciated with these problems would be to those who come In direct contact with the area. Time Required to Achieve Cleanup/Isolation: Access restriction to remnant deposit areas 1, 2 and 4 could be completed in one construction season. Detoxification of deposits 3 and 5 would be conducted simultaneously in one summer season. Ability to Meet Public Health and Environmental Criteria: If performed correctly, the combined effects of detoxifying the higher concentrations of waste materials and restricting access to the other remnant areas should protect the public from direct contact with the hazardous materials on site. However, the materials still have the potential of coming In contact with rising river waters or being eroded and carried downstream. Degree of Cleanup/Isolation Achievable: A high degree of cleanup is expected for those deposits treated with KOHPEG. For the remainder of the deposits, isolation of PCBs from the environment will not be accomplished. Ability to Meet Legal and Institutional Requirements: No requirements are expected with the possible exception of local permits. Ability to Minimize Community Impacts: The surrounding communities would feel the impact of the implementation of this alternative during the applicatIon of 9—61 ------- KOHPEC. Trucks will be needed to bring the materials to the deposit areas. Noise from Implementation may disturb the community. Reduction in anxiety will not be as great as total removal or destruction because some PCBs will remain. Commercial Impacts: The commercial impact should be minimal. Costs: Detailed costs were estimated and are included In Appendix C. 9.3.2 Evaluation Procedure Using the previously discussed effectiveness measures and weighting factors, the trade—oft matrix was established for the evaluation of the remedial alternatives. An example of the cost—effectiveness matrix Is presented as Figure 9—1. The evaluation procedure was conducted in the following manner 1) The appropriate remedial alternatives were entered into the matrix. 2) Each alternative was then rated relative to the measures of effectiveness, on a 1—to—5 scale; a 5 was used as a maximum rating, while 1 was used as a minimum rating. 3) Construction costs and operation and maintenance costs were calculated for each alternative (see Appendix C). Each alternative was rated relative to the measures of cost on a 1.0 to 2.0 scale; a 2.0 was used to represent the maximum construction or operation and maintenance cost, while 1.0 represented zero cost. Intermediate costs were rated to the nearest one—tenth. 4) The final ratings for each effectiveness measure and cost measure were computed by multiplying the rating by the corresponding weighting factor. 5) The final ratings of the cost measures were summed for each alternative. Likewise, the final ratings of the effectiveness measures were summed. 9—62 ------- COST EFFECTIVENESS MATRIX FIGURE 9- I ____ cORPORATKJNJ 0 A Halliburlon Company COST MFn IIPr EFFECTIVENESS MEASURES ALTERNATIVES I- ) .4 Z I- z o 2 tE - z w o o 0 0 U) w ( i -i U) ci ii i I- 0.4 I L , (iJ o 8 U) j 5 oz 0 N WW .J0 9 i- f1 0- ho ILl — uI hi hi U i 5 4 (Lb z n -j gw o cn j O IA 0 <_ . . 0 U) U) (9 o U) U) (ii > , l Iii W ft tti Ui I-J 14 0) ‘3 TYPE OF RATING U) C, I— 4 1- U) 0 C-, I - , WEIGHTINGFACTORS — P.O 1.2 0.6 1.1 1.0 0.6 0.6 0.5 0.5 0.4 WE IGHTED RATING . = -iiiiiiiiiiiii WEIGHTED RAT I N G WEIGHTED RATING ------- 6) The overall cost—effectiveness score was obtained by dividing the final effectiveness rating sum by the final cost rating sum. The cost—effective alternative was thereby determined as the alternative with the highest score. Initially, the remedial alternatives for disposition of removed river sediments/remnant deposits were evaluated. After selection of the cost—effective alternative, the corresponding cost data was Included with the river dredging and remnant deposit alternatives. A separate evaluation was conducted for single and combined alternatives for in—river sediments, and a separate evaluation was conducted for single and combined alternatives for the remnant deposits. The final recommendation was based on the cost—effective remedial alfernatlve from each of the two analyses. A flow diagram which depicts the evaluation procedure is presented as Figure 9—2. Completed matrices used in the cost—effectiveness analyses are presented In Appendix B. A summary of the cost—effectiveness ratings is presented as Table 9—2. 9.3.3 Selection of Cost—Effective Alternative A review of previously developed and new alternatives Is detailed In Chapter 8 of this report. Those alternatives that were maintained following the initial screening underwent detailed evaluation as described in Section 9.3.1. The selectIon of the cost—effective alternative is a result of the evaluation procedure summarized herein. During the final evaluation, it became obvious that although the KOHPEG process had passed the initial screening, the detailed analysis found that the process was extremely costly. For this reason, and also because the process was unproven, the KOHPEG process was screened out 9-64 ------- KOHPEO I II1CI ERATlON I REMEDIAL ALTERNATIVE EVALUATION - FLOW DIAGRAM HUDSON RIVER PCB SITE, HUDSON RIVERI NY NUB _CORPORAT N 0 A Halliburton Company WET AIR L TI SECURE LAMWILL DISPOSAL I a) Ill FIGURE 9-2 ------- TABLE 9-2 SUMMARY OF COST-EFFECTIVENESS RATINGS DISPOSAL ALTERNATIVES Cost—Effectiveness Alternative Rating Detoxification with KOHPEG Detoxification with Wet Air OxidatIon 6 .6 Destruction by IncineratIon 7. 1 Secure Landfill Disposai 7.1 RIVER SEDIMENT ALTERNATiVES Dredging of 40 Hot Spots 5.3 Reduced Scale Dredging 5.9 No Action. Water Supply is Not Treated 7.9 No Action, Water Supply is Treated 7.9 REMNANT DEPOSIT ALTERNATIVES Total Removal 7.5 Partial Removal 6.1 Restricted Access 5.6 In—Place Containment 8.3 In—Situ Detoxification — Partial No Action/Partial Restricted Access 5.3 Partial Removal/Partial In—Place Containment 7.0 Partial Removal/Partial Restricted Access 6.4 Partial In—Place Containment/Partial Restricted Access 7.3 Partial Containment/Partial tn—Situ Detoxification — Partial Removal/Partial In—Situ Detoxification — Partial Restricted Access/Partial In—Situ Detoxification — 9—66 ------- The evaluation matrices for the alternatives which were considered are found in Appendix B. Alternatives for disposal, dredging, and remnant areas were evaluated separately. As discussed before, a rating of 5 was given to those alternatives as the maximum favorable ranking. The cost—effective alternative was selected from the overall cost—effectiveness score by ranking the cost and effectiveness ratings. The alternatives listed below are the conclusions resulting from the matrix analysis for the Hudson River PCB site. Disposal of Contaminated Material: Secure Landfill . If, as a result of the other two evaluations, contaminated material was removed and had to be disposed of, landfilling and incineration would be found to be approximately equal in terms of cost—effectiveness. However, since incineration is an order of magnitude more expensive than landfilllng, the secure landfill disposal alternative will be the recommended remedial action for disposal. • River Sediments No Immediate Corrective Action with Further Study . It was found that the no remedial actiona alternative was the cost— effective solution although further sampling will be required to adequately determine the effects of contaminated sediments upon the local Inhabitants. Based on existing data, the contamination in its current location does not appear to pose undue risk to local inhabitants and may not justify the large sums of money needed to accomplish removal. Because, available data Is sparse and/or outdated, a two—phase remedial investigation should be performed to further characterize the locations, pathways, and quantities of PCBs present. During the InitIal phase, drinking water, air, wetlands, terrestrial vegetation, and fish samples should be taken to define the Impact of PCBs on potential receptors. If analysis of Phase I data shows a major health impact, the second phase of the Remedial investigation may be implemented, which would consist of sediment sampling and bed—load movement analysis. An environmental monitoring program should be implemented to monitor concentrations of PCBs in drinking water, fish flesh, and dredge spoils. A treatability 9-67 ------- assessment of the Waterford water supply will be conducted on the basis of historical information and data obtained from the recommended sampling program. • Remnant Deposits: In—Place Containment . In—situ capping of the contaminated deposits was determined to be the cost—effective alternative for the remnant areas. The capping would include the placement of 18 inches of subsoil, followed by 6 inches of topsoil and revegetation. These measures would serve to minimize erosion, leaching, and air transport of PCBs. In addition, all appropriate river banks would be riprapped,” in order to eliminate remnant deposit scour during high— river flows. Biannual Inspection of the cover is also reàommended in order to identify any erosion/damage of the cover material. 9.3.4 Sensitivity Analyses Sensitivity analyses were conducted in order to assess the potential effects of variation of the numerical elements within the cost—effectiveness matrix on the overall rankings of the alternatives. The variations were intended to reflect the uncertainty of the assumptions made during the rating of the alternatives, since these assumptions were based on the accuracy of investigative/sampling data and on the predIction of the future behavior of the remedial technology. Elements of the cost—effectiveness matrix which were varied include: • weighting factors • costs • numerical ratings of effectiveness measures The weighting factors were individually varied in both an upward and downward direction, as were the individual cost and effectiveness ratings. A separate analysis was conducted for the detoxification/destruction/disposal alternatives, river sediment alternatives, and remnant de osit alternatives. 9—68 ------- • Detoxification/destruction/disposal alternatives : It was previously determined that landfilling and incineration scored equally in terms of cost—effectiveness. Accordingly, small changes in the cost and effectiveness weighting factors, on the order of 0.1, were found to vary the overall rankings. Similar variations were observed when changes of 0.1 were made in the cost ratings, or changes of 1.0 were made in the effectiveness ratings. • River sediment alternatives : The sensitivity analysis indicated that the selection of one of the two no—action alternatives, as opposed to the two dredging alternatives, was not sensitive to large changes in the weighting factors or ratings. V riations of the weighting factors by 0.5, the cost ratings by 0.5, or the effectiveness ratings by 2 had no effect on the recommendation of a no—action alternative. However, the two no—action alternatives received equal overall ratings. A cordingly, variations as small as 0.1 in the effectiveness weighting factors, 0.1 in the cost ratings, or 1 in the effectiveness ratings were significant to the final ranking of these alternatives. • Remnant deposit alternatives : It was determined that the selection of the in—place containment alternative was not influenced by large variations of the cost/effectiveness weighting measures (variations of up to 0.5) or effectiveness rating.s (variations of up to 2). Variations of greater than 0.2 in the cost ratings of the in—place containment alternative were found to switch the top ranking to the total remnant deposit removal alternative, however. 9.3.5 Summary In summary, the authors have applied the guidelines of the NCP to identify a series of cost—effective remedial actions which are applicable to the Hudson River PCB problem. 9—69 ------- In Sections 3.0 through 5.0 of the Feasibility Study, the authors drew upon existing information to evaluate public health and environmental effects and health and welfare concerns associated with the problem. A major conclusion of that effort was that the present health impacts associated with PCB In air and water were low. Another conclusion was that although PCB contamination in fish, as well as other organisms, was high, previously imposed State regulations on fishing and State advisories on consumption of fish could be a cost—effective remedy. particularly In view of the fact that such measures would likely be required for some period after any type of remedial action. It was also concluded that levels of PCB in fish and air, as well as PCB transport, have declined much more rapidly than had been anticipated. It was concluded that the impact of the PCB problem in activities such as routine maintenance dredging had been overstated. In the next step (Sections 7—8), the authors drew—up a list of possible remedial alternatives. This list included all previously proposed methods, as well as some newly developed alternatives——including some promising PCB detoxification destruction techniques. The reliability, technological feasibility, possible adverse effects, and relative effectiveness in minimizing threats of the methods were reviewed. As a result, only technically feasible and promising processes were passed on to the next level of screening. Four disposal alternatives were proposed for further study: 1) Detoxification of Removed Sediments with KOHPEG; 2) Detoxification of Removed Sediments by Wet—air Oxidation; 3) Destruction of Removed PCBs by Incineration; and 4) Secure Landfill Disposal. Twelve remedial alternatives were proposed for the remnant deposits. These alternatives consisted of various combinations of 1) No—Remedial—. Action; 2) Restricted Access; 3) in—place containment; 4) In—situ Detoxification; and 5) Removal methodologies. Also, four river—sedIment alternatives, two dredging options, and two No—Remedial—Action options were considered. The No— Remedial—Action alternatives were included in the final analysis on the premise 1) that present public health impacts appeared to be low; 2) that environmental effects appeared to be decreasing without any remedial action; 3) that limited clean—up afforded by other alternatives might not result in a significant 9—70 ------- improvement over no—remedial action; and 4) that removal and dredging options could produce adverse short—term effects. In Section 9, a detailed analysis of the proposed alternatives was carried out. This analysis required the development of a conceptual design for each alternative, a more detailed estimation of costs, and a closer assessment of engineering implementation in relation to the ability of alternatives to satisfy the effectiveness criteria used in the evaluation. The detailed screening used a cost— effectiveness matrix analysis developed for the EPA specifically for the Superfund program. The evaluation resulted in a recommended alternative for.covering the remnant sites with 18 Inches of subsoil, six inches of top soil, and revegetating; and performing an analysis to assess the need and design parameters for upgrading the Waterford Water Supply. The matrix evaluation also resulted in the Identification of a no—remedial—action alternative for river sediments as the most cost—effective option. This was interpreted to mean that the limited improvement which might be expected after a dredging program does not justify the cost to implement such a program, especially In light of the present low and decreasing health and environmental impacts of the PCB problem. A sensitivity analysis was performed on the matrix analysis to determine what effect changes in costs. or effectiveness measures might have on the recommended alternatives. It was found that significant changes either in cost or in effectiveness ratings would not change the recommended alternative for river sediments. Changes In effectiveness measures by a factor of 2 and In the costs by a 20 percent variance would not change the recommended alternative for remnant deposits. 9—71 ------- 10.0 REMEDIAL AC110N PLANNING ACTIVITIES 10.1 Site Remediation Objectives One objective of the site remediatlon activities discussed in the Hudson River PCBs Site RAMP is to eliminate direct human contact with contaminated remnant deposits by covering or restricting access to them. Another objective Is to assess possible health impacts from the contaminated sediments through one phase of a Remedial Investigation (Section 9.3.3). In the event studies identify a significant health impact in the Upper Hudson River area, the second phase of the Remedial Investigation should be conducted. The purpose of this phase should be to locate PCBs in the river sediments and to identify bed—load transport rates. Details on the proposed Remedial Investigation can be found in Section 10.3, Section 10.4, and Appendix D. 10.2 Remedial Action for the Hudson River PCBs Site 10.2.1 Final Design The remedial action selected as a result of the remedial alternative evaluation consists of: (1) covering 4 remnant areas (areas 2, 3, 4, and 5) with approximately 18 inches of subsoil and about 6 inches of topsoil, and subsequently revegetating these areas; and (2) no remedial action on the contaminated river sediments. However, it is recommended that a Remedial Investigation be conducted to better quantify any potential health or environmental impacts associated with the sediments. In addition, a treatability assessment of the Waterford Public Water supply is recommended. It is also recommended that the NYSDEC and USGS fish and rlverwater sampling programs be continued. The Remedial Investigation includes monitoring of drinking water, air, terrestrial vegetation and sediments proposed for routine maintenance dredging. A wetlands study, including the collection and analysis for PCBs of vegetation, macroinvertebrates, and fish, should be implemented to determine the importance of wetlands (which in many 10—1 ------- cases are highly contaminated) in the present PCB problem with the Hudson River fishery. The remnant area remedial action includes a Remedial Investigation of the remnant areas in order to delineate the areat extent of the contaminated sediments. Elements which should be included in the proposed Remedial Investigation are described in Section 10.3. Once the Remedial Investigation is completed, detailed design specification activities will take place. A suitable borrow area from which soil will be taken will be searched for and located and negotiations will be conducted for its use. Quantities of fill and schedules for work will be finalized once the total area to be covered has been determined. The estimated capital cost of the remedial activities at the remnant sites is approximately $2,323,930. Operation and maintenance at the remnant deposits sites for a 20—year period will have an approximate present worth value of $1,123,790. The estimated cost for Remedial Investigation activities at the remnant sites prior to design activities is approximately $186,000 Including laboratory analyses. Environmental monitoring under the proposed Remedial Investigation is estimated to cost about $396,000 excluding costs of the NYSDEC fish monitoring program, the USGS river monitoring program and additional sediment sampling. The treatability study is estimated to cost about $120,000. Detailed cost breakdowns may be found in Appendix C under the no—action and in—place containment of remnant deposit options and in Appendix F. 10.2.2 implementation During this stage contractors will be procured and development of the borrow area will begin. This development should begin at the start of the construction season. The borrow area will be cleared and grubbed, and topsoil will be scraped off and stockpiled for future use. Subsoil will be removed and transported to the remnant areas. While the borrow area is being developed, clearing of the remnant sites 10—2 ------- should begin. No grubbing is recommended at remnant areas 2 and 3 since growth over these areas is sparse at this time. Stormwater diversion should be installed in order to prevent erosion of the remnant areas as well as to divert stormwater from running over the remnant site. Fill from the borrow area should be placed in 6—inch lifts on the remnant sites. Once the subsoil has been placed, a 6—inch layer of topsoil should be placed. followed by seeding. At the borrow area the slopes should be graded and the exposed soil should be seeded. Following construction, a continuing inspection program will be conducted of storm water diversion and of bank stabilization and erosion in order to determine the need for maintenance or repairs. The final Feasibility Study recommends a Treatability Study for the Waterford water supply. It is likely that this study would be tied in with the drinking water study of the Environmental Monitoring Program, however it Is not included as part of the Remedial investigation. It Is estimated that this study would cost about $120,000. 10.2.3 Environmental Monitoring An environmental monitoring program, including the existing NYSDEC fish and U.S.G.S. river—water monitoring programs, should be continued. Monitoring of the public water supplies obtaining water from the Hudson should be conducted on a representative basis. This would involve baseline sampling at selected public water supplies on at least a quarterly basis for two years. In addition, two other samples should be obtained: one following a major storm event during the spring season and a second similarly during the low—flow season. A number of private drinking water wells in the Upper Hudson River area should be selected and sampled also. During the following years, two or three public supplies should be selected for monitoring during high flows and low flows (spring and summer respectively) as a check to ensure that there is no dramatic increase in PCB concentrations. Air monitoring, vegetation sampling, and wetlands sampling should be carried out as described in Tasks 11, 12, and 13 under Section 10.4.3. Finally, sampling should be conducted at any proposed maintenance dredging area to determine the concentration of PCBs in 10—3 ------- the sediments proposed for dredging. This sampling is necessary in order to determine the degree of contamination and appropriate method for disposal of the sediments. The Remedial Investigation proposed in Section 10.4 includes only the air, drinking water, wetlands, and terrestrial vegetation sampling programs. It is assumed that the regular U.S.G.S. river—water and NYSDEC fish monitoring programs will continue. It Is also assumed that the State will insure that all proposed dredging areas will be adequately sampled. 10.3. PrelIminary Work Plan Outline for the Remedial Investigation of the Remnant Deposit Sites A work plan shall be prepared by the Contractor, prior to the start of the Remnant Area Remedial Investigation (RI) of the Hudson River PCBs Site. A Preliminary Outline of the proposed work plan is presented below. 10.3.1 Work Plan Summary The Work Plan Summary will present an overview of the technical, financial, and logistical requirements of the Remedial Investigation. Subsections will include: • Remedial Investigation Objectives • Scope of Work • Manpower Estimates and Cost • Schedule 10.3.2 Problem Assessment The majority of information to be included in the problem assessment has been included in this RAMP. The level of detail in this section should be sufficient to acquaint the reader with the problems associated with the site. This section will be developed from all available information, but it is not designed to be an assessment of all existing data. 10-4 ------- 10.3.3 Scope of Work An outline and specific description of each work task needed for the Remedial Investigation is provided in this section. Individual task descriptions will be expanded during the preparation of a Work Plan for the Remedial Investigation of the Hudson River. The discussion of those tasks pertaining to site activities which parallel current actions will include the description of these activities. The final task will include the Remedial Investigation report. 10.3.3.1 Preliminary Remedial Investigation Activities A total of TO tasks have been identified during the investigation of preliminary remedial activities. These activities are required before the site Remedial Investigation activities can be initiated. Additional tasks may be added during the preparation of the work plan as determined necessary due to project schedule and budget constraints. Task 1 — Prepare Remedial Investigation Work Plan The Work Plan outlines those activities of the Remedial Investigation necessary to delineate the limits and extent of contamination. Detailed manpower estimates, a schedule of remedial actions, and project costs will be provided in the Work Plan. This activity may require 450 man—hours to complete and is estimated to cost $18,930. Task 2 — Perform Community Relations Support Functions Community relations support provided by the contractor will be at the request of the EPA and may include logistical support for the planning and execution of the activities at the site and technical support to ensure that all information is accurate and current. Due to the nature of public involvement. community relations input must be flexible to accommodate fluctuations in public interest. Community relations input must also remain flexible to dovetail with technical progress at the site. 10—5 ------- The Contractor will assist the EPA in presenting the findings of the RI to the public. It is estimated that this task will require about 250 manhours and will cost about $13,900. Task 3 — Collect and Evaluate Existing Data It may be necessary to collect and evaluate additional information which was not available for the preparation of the RAMP. These data will be used in conjunction with existing reports to establish additional testing, sampling, and analyses necessary to successfully complete the RI. Additional data requirements not addressed by this Work Plan will be identified and used to complete the sampling plan. This task may require 150 man—hours, and is expected to cost about $6,700. Task 4 — Perform Health, Safety, and General Site Reconnaissance An initial site reconnaissance will be conducted by an investigation team to fully evaluate the existing site conditions. Several objectives have been identified for the site reconnaissance: • Conduct onsite start—up meeting with EPA and NYSDEC • Perform health and safety reconnaissance • Locate physical hazards and features • Evaluate site conditions for location of initial sediment sampling points This task will require about 90 man—hours to complete and will cost an estimated $6,300. Task 5 — Secure Permits, Rights of Entry, and Other Authorizations Access to the work areas will be obtained by EPA prior to initiation of site activities. A verification of property boundaries will be made to identify all property owners within the projected work area. Permits for emedial Investigation activities and onsite treatability studies will be obtained by EPA where necessary. This task may cost approximately $2,800. 10—6 ------- Task 6 — Procure Subcontractors The ground surveying program for the purposes of the determination of sample point locations and the development of topographic map(s) may be subcontracted. The subcontractors will be obtained using normal Superfund procurement procedures. The process of advertising for and evaluating bids will begin upon receipt of EPA authorization. Subcontracting arrangements will require an estimated 200 man—hours and cost an estimated $7,700. Task 7 — Develop Site—Specific Health and Safety Plan A site—specific Health and Safety Plan will be developed for the remnant deposit sites, based on guidelines established jn the contractor’s Health and Safety Manual and EPA’s Occupational Health and Safety Manual. The Health and Safety Plan could require approximately 40 man—hours to complete and cost about $2,300. The purpose of the plan will be to: • Provide safety protection requirements and procedures for site field crews and subcontractors. • Ensure adequate training and equipment to perform expected tasks. • Provide ongoing site monitoring to verity preliminary safety requirements and revise specific protection levels as required. • Protect the general public and the environment. Task 8 — Develop Site—Specific Quality Assurance Plan A Quality Assurance Plan will be developed based upon the Contractor’s Quality Assurance Project Plan. The plan will refer to or include site—specific details on sampling; field testing; surveying; chain—of—custody; sample handling, packaging, preservation and shipping; record keeping and documentation. Analysis 10—7 ------- requirements, in addition to those listed in the Contract Laboratory Program (CLP), will be given along with any other procedures needed for the Remedial Investigation. It is estimated that this task will cost about $3,500. Task 9 — Develop Site—Specific Sampling Plan A site—specific sampling plan will be developed. The plan will be related to the Health and Safety and Quality Assurance Plans and will include procedures for sampling various media expected to be found on site. If possible, definite sampling locations will be established. These locations will be based on site data obtained during the field reconnaissance and from detailed review of existing referenc e sources. This task will cost about $2,800. Task 10 — MobIlize Field Equipment The equipment needed during the Remedial Investigation will be provided by the Contractor or by subcontractors. Equipment scheduled for use may include: • SurveyIng equipment • Sampling tools and equipment • Health and safety equipment • Decontamination equipment Mobilization of field equipment Is estimated to cost about $500. 10.3.3.2 Site Remedial tnvesti atlon Activities Task 11 - Perform Ground Survey A ground survey will be performed to: • verify property lines • determine sample point locations • obtain data for the development of topographic maps 10—8 ------- Sample points wiN be located on a 100—foot grid and corresponding elevations will be determined for use in the preparation of topographic maps. The costs for this task are based on 40 hours of effort and is estimated to cost $13,800. Task 12 — Prepare Topographic Map A topographic map will be prepared using the data obtained during the ground survey. The product of this task shall be a single, scribed, double matte. 3 mil, washoff mylar with reversed image. The product shall have a horizontal scale of 1 inch = 50 feet and a contour interval of 1 foot. A grId coordinate system will be established based on the highest order of accuracy control points available in the immediate vicinity of the site. Control points to be considered include, but are not limited to, State plane coordinate system, U.S.G.S. monuments, Army map service monuments, county highway monuments, or, in rural areas, local monuments. Mapping and ground surveys will be completed in accordance with the National Map Accuracy Standards for the scale indicated. The preparation of a topographic map may require 60 man—hours and is estimated to cost $6,700. Task 13 — Collect Surface Soil Samples Soils will be sampled to determine the extent and degree of surface soil contamination. The area of the remnant deposits is about 60 acres. Samples will be taken from a 100—foot grid sampling regime at each of the remnant deposits. It is therefore assumed that a total of approximately 300 surface soil samples will be collected using either trowels or shovels. Sample depths will vary from 0 to 12 inches. All samples will undergo PCB analyses. The cost of this task is estimated to be $56,000. 10—9 ------- Task 14 — Reduce and Evaluate Data Following the applicable RI tasks, data generated during the study will be reduced and evaluated. The evaluation will be used in the production of a report to be submitted following the completion of all RI tasks. In addition, continuous data reduction and evaluation during the RI can also provide input for succeeding RI tasks. This task is expected to cost an estimated $31,900. Task 15 — Prepare Remedial Investigation Report After completion of the field investigations, all pertinent field and laboratory data will be assembled into a detailed report of the Remedial Investigation. This report will include the following items: • Objectives of the Remedial Investigation. • A description of the study areas based on the field investigations and the results of the laboratory testing. • Conclusions and recommendations of the study. Maps, figures and tables will be prepared to support the text. The Remedial Investigation report is estimated to cost $12,200. 10.3.4 Management Plan The management plan shall include the administrative and management requirements for performing the RI work activities. The principal sections of the management plan are described below. 10.3.4.1 Prolect Organization and Staffing This section descrIbes the project’s organizational plan with regard to personnel as well as the level of effort required to complete each task. The project manager will be identified as well as other key project personnel. 10—10 ------- 10.3.4.2 Prolect Rei orts The reporting requirements, including the quantity and distribution, will be specified in this section. The. reporting requirements for technical submittals, as well as financial and progress reporting requirements, will be specified. Other components include: • Procurement • Meetings • Change Orders • Community Relations Program • Quality Assurance • Health and Safety 10.3.5 Costs and Schedule The RemedIal Investigation at the remnant sites will last about 32 weeks and is estimated to cost about $186,000. A detailed breakdown of costs for each task in the Remedial Investigation will be included in the costs and schedule section of the Work Plan. Also, a Remedial Investigation project schedule will be presented. Preliminary project schedules and cost estimates are provided In Appendix F. 10.4 Preliminary Work Plan Outline for Phase I of the Remedial Investigation of the River Prior to the start of the Remedial Investigation (RI) of the Hudson River PCBs Site, a Work Plan shall be prepared by the contractor. A preliminary outline of the proposed work plan is presented below. 10.4.1 Work Plan Summary The Work Plan Summary will present an overview of the technical, financial, and logistical requirements of the Remedial Investigation. Subsections will include: 10—11 ------- • Remedial Investigation Objectives • Scope of Work • Manpower Estimates • Schedule 10.4.2 Problem Assessment The majority of the information to be included in the problem assessment has been included in this RAMP. The level of detail In this section should be sufficient to acquaint the reader with the problems associated with the site. This section will be developed from all available information, but it is not designed to be an assessment of all existing data. 10.4.3 Scope of Work An outline and specific description of each work task which is needed for the Remedial Investigation is provided in this section. Individual task descriptions will be expanded during the preparation of the Work Plan (Task 1) for the Remedial Investigation of the Hudson River. In addition, the delineation of those tasks which parallel current sampling programs will include a description of the current work and an explanation of any additional work needed to complete the task. The final task will include the preparation of the Remedial Investigation report. 10.4.3.1 Preliminary Remedial Investigation Activities A total of nine tasks have been identified during the investigation of preliminary remedial activites. These tasks must be performed before the site remedial investigation activites can be initiated. Additional tasks may be added during the preparation of the work plan as determined necessary due to project schedule and budgetary constraints. 10—12 ------- Task 1 — Prepare Remedial Investigation Work Plan The Work Plan outlines those activities of the Remedial Investigation necessary to update existing data on PCB concentrations in the river and ecosystem. Detailed manpower estimates, a schedule of remedial actions, and project costs will be provided in the Work Plan. This activity may require 450 man—hours to complete and is estimated to cost $19,000. Task 2 — Perform Community Relations Support Functions Community relations support provided by the contractor wilt be at the request of the EPA and may include both logistical support for the planning and execution of the activities at the Hudson River PCBs Site and technical support to ensure that all information is accurate and current. Because of the nature of public involvement, community relations input must be flexible to accommodate fluctuations in public interest. The contractor wilt assist the EPA in presenting the findings of the Remedial Investigation to the public. It Is estimated that this task will require about 250 man—hours and cost approximately $14,000. Task 3 — Collect and Evaluate Existing Data It may be necessary to collect and evaluate additional information which was not available during the preparation of this RAMP. These data will be used in conjunction with existing reports to establish additional testing, sampling, and analyses necessary to successfully complete the RI. After collection of all available information, an evaluation of the data base adequacy will be made regarding area contamination. Additional data requirements not addressed by this Work Plan will be identified and used to complete the sampling plan. This activity may require about 150 man—hours and is estimated to cost about $6,700. 10—13 ------- Task 4 — Develop Site—Specific Health and Safety Plan A site—specific Health and Safety Plan will be developed based on the available site information, guidelines established in the contractor’s Health and Safety Manual, and EPA’s Occupational Health and Safety Manual. The purpose of the plan will be to: • Provide minimum safety protection requirements and procedures for onsite field crews and subcontractors. • Ensure adequate training and equipment to perform expected tasks. • Provide ongoing site monitoring to verify preliminary safety requirements and to revise specific protection levels as required. • Protect the general public and the environment. The Health and Safety Plan will cost an estimated $5,500. Task 5 — Develop Site—Specific Quality Assurance Plan A site—specific Quality Assurance Plan will be developed based on the available site information and the guidelines established in the contractor’s Quality Assurance Manual. The Quality Assurance Plan will be designed to incorporate the following objectives: • To maintain the evidentlary value of the data produced. • To ensure the integrity of the results of site investigations, laboratory analyses, and technical reports. 10—14 ------- e To provide assurance that remedial designs and assessments are properly - prepared and reviewed. • To control the activity of subcontractors, consultants, and support agencies or organizations to ensure that they maintain the same quality standards applied to the Nt iS activities. This task may require 60 man—hours and is expected to cost approximately $2,800. Task 6 — Develop Site—Specific Sampling and Analyses Plan A site—specific sampling plan will be developed. The plan will be related to the Health and Safety and Quality Assurance Plans and will include procedures for sampling various media expected to be found in the river basin. Definite sampling locations will be established, if possible, for the air, surface - water, groundwater, and sediment samples. Locations will also be determined for the fish, macroinvertebrate, and vegetation surveys. These locations will be based on site data obtained from a review of existing data and additional data obtained from personal observation. The site specific Sampling and Analysis Plan will require an estimated 200 man—hours and is estimated to cost $2,800. Task 7— Procure Subcontractor(s) Bid documents (Plans & Specifications) will be developed and competitive bids will be solicited from prequailfied firms for each task to be subcontracted. The process of advertising for and evaluating bids will begin upon receipt of EPA authorization. The Contractor will review the bids and select the subcontractor. The EPA Contracting Officer will review and approve the subcontractor selection prior to award of the subcontract. 10—15 ------- The following elements of work are under consideration for subcontracting: • Wetland study • Model development for assessment of PCB movement in the wetlands. Subcontracting arrangements are estimated to cost approximately $8,900. Task 8 — Secure Permits, Rights of Entry, and Other Authorization Requirements Access permission to the work areas will be obtained prior to initiation of site activities. Permits for Remedial Investigation activities and onsite treatability studies will be obtained where necessary. This task is estimated to cost $5,900. 10.4.3.2 Site Remedial Investigation Activities Task 9 — Mobilize Field Equipment The equipment needed during the Remedial Investigation will be provided by the Contractor or by subcontractors. Equipment scheduled for use includes: • Field office • River transportation • Surveying equipment • Sampling tools and equipment • Health and Safety equipment • Decontamination equipment Equipment may be stored on site in a secure field office trailer. The placement of the trailer will be specified in the site—specific Health and Safety Plan. Mobilization may cost approximately $500 although this cost depends on the availability of NYSDEC equipment already purchased for the monitoring the Hudson River PCB problem. 10—16 ------- Task 10 — Collect Drinking Water Samples Present Sampling Efforts There is, at present, only limited potable—water monitoring of public or residential water supplies. Description The sampling of public and residential potable—water supplies for PCBs will be conducted to determine whether any health hazard exists In the use of water from surface or groundwater resources. Public water supplies are drawn from surface water intakes along the river, while private supplies are drawn from local aquifers. Public drinking—water sampling should be conducted quarterly and also during periods of high (spring) and low (fall) flows. This should be done to include those periods of high—sediment PCB transport potential (high— Iver flows) and high dissolved PCB—trarisport potential (low—river flows). It may onlV be necessary to sample residential wells once during the low—flow period when dissolved PCB is most prevalent in the river. Method Residential wells should be sampled at the well head or just before the holding tank. Before taking the sample, the water should be run for five minutes to ensure that a true sample of the aquifer Is taken. Sampling techniques should conform to those specified in the Contractor’s Quality Control Procedures Manual (NUS QCP 11—1, 1983). It will be necessary to conduct a well—location survey to determine which wells should be sampled. Approximately 30 wells are suggested. Public . water system sampling will include the influent, effluent, and waste discharge waters. At least three supplies, including Waterford should be sampled. Each sample should be taken at the same approximate time during each sample visit. Sampling techniques will be similar to those mentioned above, as referenced 10—17 ------- in the Contractor’s Quality Control Procedures Manual. Costs for this task ($35,000) are for one year only and are based on 300 manhours and 75 samples. Costs could change if local technicians are to be used. Task 11 — Collect Air Monitoring Samples Present Sampling Efforts There are, at present, no ongoing air monitoring programs to detect volatile or particulate—borne PCBs in the Hudson River Basin. Description The transport of PCBs into the air is accomplished by two mechanisms: volatilization, and suspension on dust or other small particles. An air monitoring program will be conducted to determine the extent of PCB volatilization or particulate suspension throughout specifically designated areas of the Upper Hudson. Ambient, levels of PCBs will be determined for residential and agricultural areas. This monitoring will be conducted during the months of highest potential PCB volatilization (July and August). The following is a list of suggested areas of study. • Thompson Island and local dams and pools, including the following: — area homes — shore areas/farmland — riffles or rapid areas Methods A sampling program of this nature should include four sampling sessions (every other week) in approximately 10 to 15 sampling locations. The focus of this effort should include those areas having the highest potential for airborne PCB 10—18 ------- concentrations. Those areas of greatest concern would include homes or farmland near riffle or rapid areas, and those areas directly below high turbulent areas, such as dams. Each sample should be collected by drawing air through a Fluorasil tube in which volatile PCBs are trapped. Particulates laden with PCBs are adsorbed next on a filter. After exposure, the sample tube and filters will be shipped to a lab where the PCBs will be desorbed from the cartridge with hexane. The resulting solution will be analyzed by gas chromatography (GC)(NIOSH, 1983). In addition to the sampling for PCBs, local weather conditions should be measured. The parameters included should be: wind speed and direction, temperature, dew point, solar radiation, rainfall, and barometric pressure. This task is estimated to cost $24,000. Again, costs could change if local technicians are used. Task 12 — Perform Wetland Study Subtask 1 — Fish Sampling Present Sampling Efforts There are at present no fish sampling programs being conducted specifically for fish which feed in the wetlands. Description The game fish that feed in the wetland areas of the Hudson represent a large part of the recreational fishing potential of this area. These fish consume the majority of their total food intake in the wetlands, and along with that, possibly the largest portion of their PCB intake. To determine this, a modeling program will be conducted including all the elements of the wetland food chain. At this time, the wetlands to be studied are unknown. For costing purposes it has been assumed that nine wetlands with differing characteristics would be studied. The selection of wetlands will be made in cooperation with NYSDEC biologists. 10—19 ------- The objective of this study will be to determine the extent to which recreational and commercial fish are adversely affected by PCBs originating in the sediments of the wetlands. For this purpose an attempt will be made to correlate fish—flesh PCB concentrations with sediment (subtask 4) and “lower food chain organism” (subtask 2) PCB concentrations. A determination should then be made as to the importance of the wetlands in regard to the PCB balance in the aquatic food chain. Method The methods to be used for the fish sampling are similar to those described in the NYSDEC Environmental Monitoring Plan (NYSDEC, April 1982). Sampling will Involve the electro—shocking of wetland game fish. The fish will be collected and frozen for later analysis. The fish will first be counted, then separated according to species; later the flesh of each fish will be analyzed for its PCB content. In addition the stomach of each fish will be analyzed to determine the dietary content and the PCB concentration of the food. This analysis, in combination with the results of the study of Hudson River macroinvertebrates (subtask 2), can be used to determine PCB transport through the wetland food chain. Costs for this subtask ($70,000) are based on 480 hours of effort and 180 samples. Costs could change depending on the availability of State equipment and technicians. Subtask 2 — Macroinvertebrate Study Present Sampling Efforts New York State eaâh year conducts a macroinvertebrate study of the Hudson River, but this study is not specifically designed for wetland macroinvertebrates. Description The wetland benthic community may comprise a large component of the Hudson River game fish diet. The communhiy s potentially a continuous source of PCB contamination in these fish, and, in effect, the predators of these fish (animals, birds, larger fish) as this contamination moves up the food chain. By equating 10—20 ------- wetland macroinvertebrate PCB content with fish—flesh and stomach analysis results (subtask 1), a relationship may be determined (via modeling), revealing the mechanism of PCB transport through the food chain. Method Wetland sampling will be conducted according to the schedule currently followed by the State. Samples are collected at 5—week intervals during the sampling season (June—September) (NYSDEC, April 1982). Macroinvertebrate organisms will be collected by three methods: multiplate, dlpnet, and bottom dredge sampling. Used to collect a large varIety of insect larva, the multiplate sampler consists of a series of parallel concentric plates, which act as an artificial substrate for the development of macroinvertebrate communities. Placed under water in the wetlands for approximately two weeks, small colonies develop on the hardboard plates of the sampler. After the removal of the sampler from the river, the plates are separated and an inventory of the colonized organisms is taken——identifying species diversity——and afterward representative samples of the organisms are taken and analyzed for PCB content (NYSDEC, April 1982). Caddisfly larvae (not collected by the muitiplate sampler) are collected with a D—frame aquatic dipnet or by picking tI le larvae directly off rocks removed from the river (NYSDEC, April 1982). An inventory and analysis is performed as noted above, In addition, organisms living in the sediments will be sampled using a bottom dredge (small mechanical clam—shell), and the organisms will be separated from the sediments by screening. Samples will first be separated according to species and later analyzed for PCB content. This subtask is estimated to cost about $34,000. 10—21 ------- Subtask 3 — Wetland Vegetation Sampling Present Sampling Efforts Presently there is no information on the PCB content of wetland vegetation. Malcolm Pirnie (1980) indicated that PCB uptake by marshland vegetation would be minimal. PCB analysis of terrestrial vegetation, however, indicates that absorption of airborne PCBs can result in PCB levels in foliage which are significantly higher than background levels. Description Wetland vegetation sampling will consist of compositing stem and foliage samples from species occupying each of the wetland areas in question and analyzing them for PCBs. Methods At each wetland area, 20 stem and leaf subsamples from resident species will be collected and composited to form two samples for analysis. Collections will be made near the end of the growing season in September so the total accumulation of PCB will be determined. Sample preparation and analysis will be done according to the procedures described under terrestrial vegetation sampling. Costs for this subtask are based on 18 samples and are estimated at $26,000. Subtask 4 — Wetland Sediment Sampling Present Sampling Efforts There are, at present, no sediment sampling programs being conducted to quantify PCB contamination in the wetlands. 10—22 ------- Des cr1 ptlon A sediment sampling and analysis program will be conducted to determine the extent of PCB contamination throughout certain wetland areas of the Upper Hudson. The results of this sampling, used in conjunction with the results of the other sampling programs (subtasks 1 through 3), will be used to determine the pathways and amount of PCB transport through the food chain from the wetlands. The sediment sampling effort is paramount to the other tasks In that, without an adequate determination of PCB concentrations in the organic sediments of the wetlands, an accurate trace of PCB movement through the food chain would be impossible. In other words, large errors made in the determinatlon of PCB concentrations and volumes in the sediments indigenous to the wetlands will invalidate any assumptions made about the importance of the wetlands in the food chain transport system. To effectively establish an adequate data base, the sampling program should include extensive sample coring and wetland staking efforts. The sample cores will be taken to quantify the distribution and depth of contamination, while a staking program will delineate net deposition or scour in given wetland areas. Method Sample cores will be taken in relatively undisturbed areas of the wetlands. Samples should be taken as close as possible to predetermined grid locations. At each location a three—foot core (approximately) will be taken and split by layers into subsamples, yielding three or four samples each. All of the samples will be analyzed for PCB content. In addition some of the samples will also be analyzed for particle—size class and organic content. The exact Aroclors to be analyzed for and the method for reporting total PCBs will be specified in the Work Plan. A staking program wilt be condUcted in all wetland areas. Metal stakes will be placed at specific locations in the wetlands and the depth to the sediment (from the top of the stake or a predetermined mark) will be measured on a monthly basis. 10—23 ------- As the sediment levels rise or fall in each area, an indication of net deposition or scour will be determined for areas of individual wetlands. Costs for this subtask are based on approximately 135 analyses. The estimated cost is $53,000. Task 13 — Collect Terrestrial Vegetation Samples Present Sampling Efforts In 1978 and 1979, sampling of foliage from 10 plant species (both annual and perennial types) was conducted throughout Washington and Saratoga Counties to assess the levels of accumulation of PCBs in plants. In addition, background levels of PCB in forage and row crops in four replicate plots near the proposed containment area have been studied since 1981. These studies have revealed PCB contamination significantly higher than background levels in species growing near heavily contaminated PCB disposal sites. Evidence shows that PCB contamination of plants and crops increases with decreasing distance from the river, and that these trends are related to atmospheric PCB concentrations; however, the data are inconclusive because there is no corresponding information on air monitoring. Description Foliage will be collected near the end of the growing season along road transects corresponding to those studied by Buckley (1980), near Lock 6 (Callahan Road, East Road), and up—river from Griffin Island (Clark Road). Plants along these transects have shown increases In PCB content with decreasing distance from the river. These transects also correspond to air sampling that will be performed in the area. The species to be studied include alfalfa, red clover, field corn, trembling aspen, large—toothed aspen, timothy, staghorn sumac, brome grass, orchard grass, and goldenrod. Background levels and PCB trends for these species have been reported by Buckley (1980). Multiples of background levels (MBL) (Buckley 1980) as an expression of PCB content in plants will be examined and used if appropriate. 10—24 ------- Methods From 5 to 10 sampling stations will be selected at distances corresponding to previous studies on transects placed perpendicular to the river. Vegetation sampling will take place within 10 percent of the specified distance from the river. A minimum of 20 subsamples from each species will be taken to comprise one composite sample. Appropriate duplicate samples will be taken. Sample preparation and analysis will be conducted according to methods described in the Monitoring’ Plan (NYSDEC, 1982). This task requires the analysis of 100 composite samples and will cost approximately $18,800. Task 14 — Reduce and Evaluate Data Following applicable RI tasks, data generated during the study will be reduced and evaluated. The evaluation will be used in the production of a report (Task 15) to be submitted following the completion of all RI tasks. The data reduction and evaluation process is necessary to ensure that all data obtained will be usable in the course of making conclusions or data comparisons. In addition, continuous data reduction and evaluation during the RI can provide input for succeeding RI tasks. This task will require an estimated 1,620 man—hours of effort and will cost approximately $60,800. Task 15 — Prepare Remedial Investigation Report After completion of the field investigations, all pertinent field and laboratory data will be assembled into a detailed draft report of the Remedial Investigation. This report will include the following items: • Objectives of the Remedial Investigation • Groundwater and surface water quality in the study area 10—25 ------- • A model evaluation of PCB transport through the wetland food chain • A discussion of the current levels of PCB transport to the environment via air, water, and biotic pathways as well as the health impacts of this transport. • Conclusions and recommendations of this study The Remedial Investigation Report is estimated to cost Si 1,500. 10.4.4 Management Plan The management plan shall include the administrative and management requirements for performing the RI work activities. The principal sections of the management plan are described below. 10.4.4.1 Proiect Organization and Staffing This section describes the project’s organizational plan with regard to personnel as well as the level of effort required to complete each task. The project manager will be identified as well as other key project personnel. 10.4.4.2 Proiect Reports The reporting requirements, including the quantity and distribution, will be specified In this section. The reporting requirements for technical submittals, as well as financial and progress reporting requirements, will be specified. Other components of the Management Plan Include: • Procurement • Meetings • Change Orders • Community Relations Program 10—26 ------- Quality Assurance . Health arid Safety 10.4.5 Costs and Schedule The Remedial Investigation of the Hudson RIver will require about 55 weeks to complete and will cost an estimated $396,000. These times and costs do not Include NYSDEC— and USGS—sponsored fish and water monitoring programs nor do they consider additional sediment sampling. A detailed breakdown of costs for each task in the Remedial Investigation will be included in the Costs and Schedule section of the Work Plan. Also , a Remedial Investigation project schedule will be presented. Preliminary prolect schedules and cost estimates are provided in Appendix F. 10—27 ------- REFERENCES Site—Specific Technical Giese, C. L and W. A. Hoppa, Jr., 1970. Water Resources of the Champlain — Upper Hudson Basins in New York State . U.S. Department of the Interior, Geological Survey, Albany, New York. Spagnoli, J. J. and L C. Skinner, 1975. PCBs in Fish from Selected Waters in New York State . New York State Department of Environmental Conservation, Bureau of Environmental Protection, Albany, New York. Hullar, T., R. Mt. Pleasant, S. Pagano, J. Spagnoli, & W. Stasiuk, 1976. PCB Data in Hudson River Fish, Sediments, Water and Wastewater . New York State Department of Environmental Conservation, Albany, New York. Sheppard, J. D., April 1976. ValuatIon of Hudson River Fishery Resources: Past. Present, and Future. Internal Report, New York State Department of Environmental Conservation . Bureau of Fisheries, New York State Department of Environmental Conservation, Albany, New York. Tofflemire, T. J., April 1976. Preliminary Report on Sediment Characteristics and Water Column Interactions Relative to Dredging the Upper Hudson River for PCB Removal . New York State Department of Environmental Conservation, Albany, New York. New York State Department of Environmental Conservation, March 1976. PCB Data in Hudson River Fish, Sediments, Water and Wastewater . Albany, New York. Zimmie, T. F., April 19, 1976. Hudson River Bedload Sediment Samples . New York State Department of Environmental Conservation. R- 1 ------- Texas Instruments, Inc., May 1976. A Synthesis of Available Data Pertaining to Major Physiochemical Variables within the Hudson River Estuary . Malcolm Pirnie, Inc., June 1976. Preliminary Appraisal, Sediment Transport Relations, Upper Hudson River . Prepared for New York State Department of Environmental Conservation, Albany, New York. Lawler, Matusky, and Skelly Engineers, November 1976. PCB Non—Dredging Alternative Evaluation . Prepared for New York State Department of Environmental Conservation, Albany, New York. Spagnoli, J. J. and L C. Skinner, 1977. PCBs in Fish from Sel cted Waters of New York State . New York State Department of Environmental Conservation, Albany. New York. Horstman, K. H., May 30, 1977. Evaluation of Non—Dredging Alternatives for the Removal of PCB Contamination from the Hudson River . Unpublished thesis, Rensselaer Polytechnic Institute, Troy, New York. Hydroscience, Inc., 1978. EstimatIon of PCB Reduction by Remedial Action on the Hudson River Ecosystem . Prepared for New York State Department of Environmental Conservation, Albany, New York. Malcolm Pirnie, Inc., 1978. Feasibility Report on Dredging of PCB—Contaminated River Bed Materials, Upper Hudson River, New York . Three volumes. Prepared for New York State Department of Environmental Conservation, Albany, New York. Hetling, L., E. Horn, and J. Tofflemire, April 1978. Summary of Hudson River PCB Study Results . Prepared for New York State Department of Environmental Conservation, Albany, New York. R-2 ------- Lawler, Matusky, & Skelly Engineers, September 1978. Upper Hudson River PCB No—Action Alternative Study, Final Report . Prepared for New York State Department of Environmental Conservation. Weston, November 1978. Migration of PCBs from Landfills and Dredge Spoil Sites in the Hudson River Valley, New York — Final Report . Prepared for New York State Department of Environmental Conservation, Albany, New York. Hydroscience, Inc., 1979. Analysis of the Fate of PCBs in the Ecosystem of the Hudson Estuary . Prepared for New York State Department of Environmental Conservation, Albany, New York. Lawler, Matusky, & Skelly Engineers, 1979. Upper Hudson River PCB Transport Modeling Study . Prepared for New York State Department of Environmental Conservation, Albany, New York. New York State Department of Environmental Conservation, 1979. The Water and Related Land Resources of the Hudson River Basin . Albany. New York. New York State Department of Environmental Conservation, January 1979. Hudson River PCB Study Description and Detailed Work Plan . Prepared for New York State Department of Environmental Conservation, Albany, New York. Tofllemire, 1. J., L J. Hetling and S. 0. Quinn, January 1979. PCB in the Upper Hudson River: Sediment Distributions, Water Interactions and Dredging . Prepared for New York State Department of Environmental Conservation, Albany, New York. Tofflemire, 1. J., February 1979. Summary Report on Lock 4 Dredging Monitoring . Prepared for New York State Department of Environmental Conservation, Albany, New York. R-3 ------- Toffiemire, T. J. and S. 0. Quinn, April 1979. PCB in the Upper Hudson River: Mapping and Sediment Relationships . Prepared for New York State Department of Environmental Conservation, Albany, New York. Hetling, L J., 1. J. Tofflemire, and E. G. Horn, May 31, 1979. The Hudson River PCB Problem: Management Alternatives . Reprinted from the Annals of the New York Academy of Sciences, Volume 320, pp. 630—650. Horn, E. G., L J. Hetling, and T. J. Tofflemire, May 31, 1979. The Problem of PCBs in the Hudson River System . Reprinted from the Annals of the New York Academy of Sciences, Volume 320, pp. 591—609. Tofflemire, T. J., November 1979. Improving the Efficiency of Dredging Several Feet of Contaminated Sediment Off the Top of an Uncontaminated Sediment . Prepared for New York State Department of Environmental Conservation, Albany, New York. Lawier, Matusky, & Skelly Engineers, December 1979. Upper Hudson River PCB Transport Modeling Study: Final Report . Peart River, New York. Prepared for New York State Department of Environmental Conservation. Armstrong, R. W. and R. ,J. Sloan, circa 1980, Patterns in Hudson River FIsh ’ Resident—Freshwater Species . New York State Department of Environmental Cobservation, Bureau of Fish & Wildlife. Buckley, E. H. 1980. PCBs in Vegetation . Boyce Thompson institute, Cornell University, Ithaca, New York. Gahagan and Bryant, 1980. Boring logs — Thompson Island Pool . Prepared for New York State Department of Environmental Conservation, Albany, New York. O’Brien and Gere, 1980. Environmental Monitoring Program, Hudson River Maintenance Dredging . Prepared for U.S. Army Corps of Engineers, New York District. R-4 ------- Zimmie, T. F., 1980. Determining Rates of Cohesive Sediment Erosion for the Hudson River, Final Report . Prepared for New York State Department of Environmental Conservation, Albany, New York. Tofflemire, 1. J., March 1980. PCB in Sediments and Water and their Transport, Draft Report . Prepared for New York State Department of Environmental Conservation, Albany, New York. Armstrong, R. W. and R. J. Sloan, June 1980. Trends in Levels of .Several Known Chemical Contaminants in Fish from New York State Waters . Prepared for New York State Department of Environmental Conservation, Albany, New York. Tofflemire, 1. J., August 25, 1980. Letter to I. Carcich — Wetland Sediment Work: August 21, 1980 . New York State Department of Environmental Conservation, Albany, New York. Tofflemire, 1. J., S. 0. Quinn, and I. G. Carcich, September 1980. Sediment and Water Sampling and Analysis for Toxics: Relative to PCB in the Hudson River . New York State Department of Environmental Conservation, Albany. New York. Malcolm Pirnie, Inc., September 1980. Draft Environmental Impact Statement, New York State Environmental Quali-ty Review: PCB Hot Spot Dredging Program, Upper Hudson River, New York . Prepared for New York State Department of Environmental Conservation, Albany, New York. New York State Department of Environmental Conservation, December 1980. Results of 1978 Barge Sampling In the Hudson River . Albany, New York. Armstrong, R. W. and R. J. Sloan, circa 1981. PCB Patterns in Hudson River Fish I. Resident/Freshwater Species . New York State Department of Environmental Conservation, Albany, New York. New York State Department of Environmental Conservation, circa 1981. General 1981—1985 Hudson River PCB Sampling Design for Fish Monitoring . Albany, New ‘York. R-5 ------- Sloan, R. J. and R. W. Armstrong, circa 1981. PCB Patterns in Hudson River Fish II. Migrant/Marine Species . New York State Department of Environmental Conservation, Albany, New York. Bopp, A. F., H. J. Simpson, C. R. Olsen, and N. Kostyk. 1981. Polychlorinated Biphenyls in Sediments of the Tidal Hudson River. New York . Johnson, B. J., 1981. PCBs in Hudson River Sediments . Prepared for the U.S. Environmental Protection Agency. Obrien and Gere, 1981. Hudson River Water Treatabilitv Study . Prepared for New York State Department of Environmental Conservation, Albany, New York. Turk, J. T. and D. E. Troutman, 1981. Polychlorinated Biphenyl Transport in the Hudson River, New York . U.S.G.S., Albany, New York. New York State Department of Environmental Conservation, April 1981. PCB Desorption from River Sediments Suspended During Dredging . Albany, New York. Tofflemire, 1. J., April 20, 1981. Letter to I. Carcich — Darmer PCB Summary . New York State Department of Environmental Conservation, Albany, New York. Zimmie, T. F., May 1981. Determining Rates of Cohesive Sediment Erosion for the Hudson River . Prepared for New York State Department of Environmental Conservation, Albany, New York. Tofflemire, T. J., October 14, 1981. Letter to Mr. Carcich — PCB Hot Spot Maps — New Contour Line at 20—25 ppm . New York State Department of Environmental Conservation, Albany, New York. New York State Department of Environmental Conservation. December 1981. Volatilization of PCB from Sediment and Water: Experimental and Field Data . Albany, New York. R-6 ------- Tofflemira, T. J., and M. B. Werner. March 29, 1982. Letter to Mark Brown — Analysis of U.S.G.S. 1980—1981 Water Year Data . New York State Department of Environmental Conservation, Albany, New York. New York State Department of Environmental Conservation, AprIl 1982. Industrial Hazardous Waste Facility Siting Board—Decision . Albany. New York. New York State Department of Environmental Conservation, May 1982. Department of Environmental Conservation Decision . Albany, New York. New York State Department of Environmenta’ Conservation. August 1982. Environmental Monitoring Program, Hudson River PCB Reclarriation Demonstration Proiect . Albany, New York. Malcolm Plrnie, Inc., 1983. Hudson River Federal Channel Maintenance Dredging . Prepared for Department of the Army, New York District Corps of Engineers. Tofflemire. T. J., March 16, 1983. Letter to Mr. Carcich — 1981—82 Year Water Data from U.S.G.S . New York State Department of Environmental Conservation, Albany, New York. Brown, M. P. and M. B. Werner, April 1983. Recent Trends in the Distribution of Polychlorinated Biphenyls in the Hudson River System . Prepared for New York State Department of Environmental Conservation, Albany, New York. Tofflemire, T. J., May 10, 1983. Letter to Mr. Carcich — Summary of Hudson Pool Elevations During May 2—5 Flood . New York State Department of Environmental Conservation, Albany, New York. Tofftemire, 1. J., May 31, 1983. Letter to J. Werling of NUS Corporation — Recommended Sample Locations . New York State Department of Environmental Conservation, Albany, New York. R-7 ------- Drew, R. S., June 1983. Letter to J. Werling of NUS Corporation — Hudson River PCB Dredging Reclamation Proiect . New York State Department of Environmental Conservation, Albany, New York. McArthur, R., June 1983. Personal Communication with J. Yeasted of NUS Corporation . Hydrologic Engineering Center. Davis, California. Treiling, K. S., July 6, 1983. Letter to J. Werling, NUS Corporation — Design Specifications and Monitoring Data for the Moreau Dredge Disposal Site . New York State Department of Environmental Conservation, Albany, New York. Shuckrow, A. J., July 8, 1983. “ PCB Immobilization, Detoxification, Degradation, and Destruction — Technological Advances Since 1980. ” Prepared for NUS Corporation by Michael Baker, Jr., Inc., Beaver, Pennsylvania. Tofflemire, 1. J., no date. Lower Hudson River PCB Data . New York State Department of Environmental Conservation, Albany, New York. Community Relations/Legal Stuart, A., May 19, 1983 “U.S. sued for funds to clean up Hudson.” The Knickerbocker News . Albany, New York. Non—Site—Specific Cushman, 1950. The Groundwater Resources of Rensselaer County. New York . NYS Water Power and Control Commission, Bulletin GW—21. Cushman, 1953. The Groundwater Resources of Washington County, New York . NYS Water Power and Control Commission, Bulletin GW—33. R-8 ------- Heath, R. C., F. K. Mack. and J. A. Tannanbaum, 1963. Groundwater Studies in Saratoga County, New York . NYS Department of Conservation Water Resources Commission, Bulletin GW—49. Chow, V. T., 1964. Handbook of Applied Hydrology . McGraw Hill, Inc., New York, New York. Suggs, I. D., D. H. Petersen, and J. B. Middlebrook, Jr., 1972. Mercury Pollution Control in Stream & Lake Sediments, USEPA Water Pollution Control Research Series 16080HT D7427 . Washington, D.C. United States Department of Agriculture Soil Conservation Service, 1975. QJj Survey of Washington County, New York . Washington, D.C. U.S. Army Corps of Engineers, 1976. Operating Manual for HEC—6 Model . Hydrologic Engineering Center, Davis, California. U.S. Department of Health, Education, and Welfare, National Institute for Occupational Safety and Health (NIOSH), April 1977. NIOSH Manual of Analytical Methods . U.S. Department of Health, Education, and Welfare, Cincinnati, Ohio. National Research Council, 1979. Polychlorinated Biphenyls . National Academy of Sciences. Zimmie, T. F., 1979. Measurement of Toxic Substances Transport via Bedload Sediment . Rensselaer Polytechnic Institute, Troy, New York. Shen, T. and T. J. Tofflemire, March 1979. Air Pollution Aspects of Land Disposal of Toxic Waste . Prepared for New York State Department of Environmental Conservation, Albany, New York. Arismen, R. K., R. C. Music, General Electric; J. D. Zeff, T. C. Crase, Westgate Research; May 1980. “Experience in Operation of an Ultraviolet—Ozone (Ultox) Pilot Plant for Destroying Polychlorinated Biphenyls in Industrial Waste Influent.” R-9 ------- Proceedings — 35th Industrial Waste Conference , Purdue University, Lafayette, Indiana. Miller. R. A., J. D. Johnson, R. W. Helsel, and D. M. PiUs, May 1980. “Destruction of Toxic Chemicals by Catalyzed Wet Oxidation.” Proceedings — 35th Industrial Waste Conference . Purdue University, Lafayette, Indiana. Goodyear Tire and Rubber Company, September 1980. A Safe, Efficient Chemical Disposal Method for Potychlorinated Biphenyls — PCBs . Akron, Ohio. National Oceanic and Atmospheric Administration, 1981. Local Climatological Data Annual Summaries for 1981 . Asheville, North Carolina. Niagara Mohawk Power Corporation, January 1981. Position Paper . Syracuse, New York. Valentine. R. S., February 1981. “LARC — Light Activated Reduction of Chemicals” Pollution Engineering . Atlantic Research Corporation. Edwards, B. H., J. N. Pacellin, and K. Caghlan—Jordan, March 1981. “Emerging Technologies for the Destruction of Hazardous Waste — Ultraviolet/Ozone Destruction.” Proceedinq of EPA Seventh Annual Research Symposium . Barton, T. C., and C. P. Arsenault, May 1981. “Toxic Waste Destruction by Plasma Pyrolysis. Proceedings — 36th Industrial Waste Conference , Purdue University, Lafayette, Indiana. Hornig, A. W., May 1981. Decomposition of Chlorinated Hydrocarbons Using a Novel High—Temperature Fluid Wall Reactor.” Proceedings — 36th Industrial Waste Conference , Purdue University, Lafayette, Indiana. New York State Department of Environmental Conservation, June 1981. Toxic Substances in Fish and Wildlife: 1979 and 1980 Annual Report , Vol. 4, No. 1. Albany, New York. R- 10 ------- Randall, T. L, June 1981. lNet Oxidation of Toxic and Hazardous Compounds. Proceedings — 13th Mid—Atlantic Industrial Waste Conference . Berry, R. J., August 10, 1981. “New Ways to Destroy PCBs.H Chemical Engineering , Vol. 88, No. 16, New York, New York. Lihach, N., October 1981. Managing PCBs . ” EPRI JournaL Vol. 6, No. 8, Palo Alto, California. New York State Department of Environmental Conservation, December 1981. Toxic Substances in Fish and Wildlife: May 1 to November 1, 1981. Volume 4, No. 2 . Albany, New York. Brown, M. P., J. A. McLaughlin, and J. M. O’Connor, 1982. A Mathematical Model of PCB Bloaccumulation in Plankton . Elsevier Scientific Publishing Company, Amsterdam. Rand McNally, 1982. Road Atlas . Rand McNally and Company, Chicago, Illinois. Craddock, J. H., March 8—10, 1982. Polychlorinated Biphenyls (PCBs) Disposal and Treatment Technologies — An Update . Presented by Monsanto Company at the Fertilizer institute Environmental Symposium. Fradkin, L, and S. Barisas, June 1982. Waste Management Options for PCBs.# Proceedings — 14th Mid—Atlantic Industrial Waste Conference . Argonne National Laboratory. New York State Department of Environmental Conservation, June 1982. Toxic Substances in Fish and Wildlife, November 1, 1981 to Aprrl 30, 1982 . Vol. 5, No. 1: Albany, New York. Battelle Pacific Northwest Laboratories. July 1, 1982. Amine—Enhanced Photodegradation of Polychlorinated Biphenyls EPRI Report CS2513. R—1 1 ------- Johanson, J., September 1982. “Molten Salt Destruction of PCBs. Proceedings: 1981 PCB Seminar , EPRI Report EL2572. Matovich, E., September 1982. “Treatment of PCB—Contaminated Soils with the Thagard High—Temperature Fluid — Wall Reactor.” Proceedings: 1981 PCB Seminar , EPRI Report EL2572. Miille, i3. J., September 1982. “Chemical Decomposition of PCBs in Transformer Fluids: The Acurex process.” Proceedings: 1981 PCB Seminar , EPRI Report EL 2572. O’Connor, J. M., December 17, 1982. Evaluating of Capping Operations at the Experimental Mud Dump Site, N.Y. Bight Apex, 1980 . New York University Medical Center Institute of Environmental Medicine, Tuxedo, New York. Brunelle. D. J. and D. A. Singleton, 1983.- “Destruction/Removal of Poly— chlorinated Biphenyls from Non—Polar Media. Reaction of PCB with Polyethylene GlycoI/KOH. ” Chemosphere , Vol. 12, No. 2. Schink. B. and M. Stieb, June 1983. “Fermentative Degradation of Polyethylene Glycol by a Strictly Anaerobic Gram—negative, Nonsporeforrning Bacterium.” Applied and Environmental Microbiology , Vol. 45, No. 6, University of Konstanz, West Germany. Greene, R., July 11, 1983. “CE Alert: New Technology.” Chemical Engineering , Vol. 90, No. 14, New York. New York. Hague, R., 0. W. Schmedding and V. H. Freed, no date. Aqueous Solubility, Adsorption and Vapor Behavior of Polychlorinated Biphenyt Aroclor 1254 . Oregon State University, Corvallis. Oregon. NUS Corporation, Superfund Division. 1983. Quality Control Procedures Manual . NUS Corporation, Pittsburgh, Pennsylvania. R— 12 ------- APPENDIX A SITE CHRONOLOGY HUDSON RIVER PCBs SITE. NEW YORK ------- APPENDIX A SITE CHRONOLOGY HUDSON RIVER PCBs SITE. NEW YORK 1822 Fort Edward Dam completed. 1898 Fort Edward Dam reconstructed. 1950—1970 Navigational dredging removes an average of 23,000 cubic yards of sediment per year in Ford Edward area. 1950—1976 General Electric discharges approximately 500,000 pounds of PCBs into Hudson River from two capacitor plants in Hudson Falls. 1969 Elevated levels of PCBs were first discovered in Hudson River biota. December 18, 1972 General Electric applies for a discharge permit, for an average discharge of 30 pounds/day of Chlorinated Hydrocarbons. Permit became effective January 1975. Spring 1973 30,000 cubic yards of sediment dredged by contractor to Scott Paper Company. July—October 1973 Fort Edward Dam was removed because of its deteriorating condition. July 1973—July 1974 850,000 cubic yards of sediment are scoured from former dam pool and 790,000 cubic yards deposited in east and west channels near Rogers Island. A-i ------- 1974—1975 615,000 cubic yards of sediment dredged by NYSDOT from east and west channels near Rogers Island. April 1974 Attorney General of State of New York brought suit against Niagara Mohawk Power Corporation for permit violation due to excessive downstream transport of sediment and debris following removal of Fort Edward Dam. August 1974 USEPA found PCB levels in fish as high as 350 ppm in the Upper Hudson River. October 1974— Timber rock cribs removed; rock placed to stabilize July 1975 remnant deposits 3 and 4; banks shaped; dumped rock stabilized remnant deposit 5. January 1975 G.E. permit to discharge 30 pounds/day of “Chlorinated Hydrocarbons” became effective. September 8, 1975 NYSDEC brought suit against GE for PCB contamination of tI e Hudson River. 1975—1976 PCB levels in all species of fish sampled in some areas of the Hudson River were found to be exceeding the U.S. Food and Drug Administration tolerance level of 5 ppm. 1976 35,000 cubic yards dredged in the vicinity of buoy 212 by NYSDOT; fishery closed. February 9, 1976 HearIng Officer found that DEC had presented overwhelming evidence of GE’s responsibility for PCB contamination of Hudson River. A-2 ------- April 2, 1976 100—year flood occurs; additional 260,000 cubic yards of sediment scoured from unstabilized areas in former dam pool. Summer 1976 Survey of Hudson River begins and lasts until 1978 from which 40 hot spots were identified. September 8, 1976 Settlement of Hudson River PCB contamination hearing was reached. September 1976 General Electric reduces daily PCB discharges to 454 g (1.0 Ib) into Hudson River from the capacitor plants in Hudson Falls and Fort Edward. July 1977 General Electric reduces daily PCB discharges to less than 0.0022 lb into Hudson River from two capacitor plants in Hudson Falls and Fort Edward. September— 180,000 cubic yards of sediment dredged from east December 1977, channel and placed in new Moreau site, along with April—June 1978 material removed from remnant deposit 3a. April 1978 NYSDEC issued summary of Hudson River PCB study results. June—August 1978 Banks of remnant deposits 3 and 5 were restabilized. October 1978 NYSDEC removed 14,000 cubic yards of sediment from the most contaminated remnant pool deposits and deposited them in the Moreau Landfill. September 1980 Clean Water Act (CWA) amendment entitled Hudson River PCB Reclamation Demonstration Project was A-3 ------- passed by Congress; EPA was authorized to spend up to $20,000,000 toward a proposed demonstration/reclamation project for removal and disposal of PCB—contaminated sediments from the Hudson River. September 1980 Malcolm Pirnie issued Environmental Impact Statement on PCB Hot Spot Dredging Program, Upper Hudson River, New York. October 1980 CWA Section 10 Amendments passed, which authorized EPA to make grants to the NYSDEC for the Hudson River PCB Reclamation Demonstration ProjeOt. January 12, 1981 EPA — Region II issued Notice of Intent to prepare an E.I.S. May 8, 1981 EPA — Region II issued draft Environmental Impact Statement on Hudson River PCB Reclamation Demonstration Project. June 23—25. 198) EPA and Army Corps of Engineers co—chaired public hearings on the Draft E.I.S. August 28, 1981 EPA — Region II Issued Supplemental Draft to E.l.S. April 22, 1982 NYS Hazardous Waste Facility Siting Board rendered decision to approve a site for the disposal of PCB— contaminated sediments. October 8, 1982 EPA — Region II issued final E.l.S. on Hudson River PCB Reclamation Demonstration Project. A-4 ------- December 30, 1982 EPA — Region I I issued Record of Decision for the Environmental Impact Statement on the Hudson River PCB Reclamation/Demonstration Project, which switched project funding from CWA to CERCLA. April—May 1983 Return of flood flows approaching the 80—year recurrence frequency. April 27, 1983 RemedIal Action Master Plan (RAMP) was assigned to NUS Corporation by EPA. May 19, 1983 Four environmental groups and a Weschester County, New York. Congressman sue EPA for release of CWA authorized cleanup funds. June 1983 NYSDEC files intent to sue EPA for release of CWA authorized cleanup funds. August 1983 Site permit overturned. September 8, 1983 EPA added the upper Hudson River to the CERCLA list for New York State. September, 1983 Court order drops September 30, 1983 deadline for commitment or loss of CWA funds assigned to New York. A- 5 ------- APPENDIX B COST EFFECTIVENESS MATRICES HUDSON RIVER PCBs SITE. NEW YORK ------- DISPOSAL ALTERNATIVES 9.3.1.1 DETOXIFICATION OF REMOVED SEDIMENTS WITH KOHPEG’ TYPE OF RATING FACTORS INIT IAL RATING WEIGHTED RATING 9.3.1.2 DETOXIFICATION OF REMOVED SEDIMENTS WITH WET AIR OXIDATION INITIAL RATING WEIGHTED RATING 9.3.1.3 DESTRUCTION OF REMOVED SEDIMENTS BY INCINERATION INITIAL RATING WEIGHTED RAT IN G REMOVED FROM FURTHER CONSIDERATION DURING REMEDIAL ALTERNATIVES EVALUATION PROCESS COST EFFECTIVENESS MATRIX FIGURE B-I - 1NU9 _COR JR flON 0 A HaIlib; 1 Company HUDSON RIVER PCB SITE, NY ------- DISPOSAL ALTERNATIVES 9.3.1.4 SECURE LANDFILL DISPOSAL OF REMOVED SEDIMENTS COST EFFECTIVENESS MATRIX FIGURE B-2 NUB ____ ORPORATKJN 0 A Halliburlon Company HUDSON RIVER PCB SITE 1 NY ------- RIVER SEDIMENT ALTERNATIVES 9.3.1.5 DREDGING OF 40 HOT SPOTS 9.3.1.7 NO ACTION FOR RIVER SEDIMENTS ROUTINE DREDGING CONTINUES, WATER SUPPLY IS NOT TREATED COST EFFECTIVENESS MATRIX FIGURE B-3 NUB _CO flRA ON 0 A HaIlibu Company HUDSON RIVER PCB SITE,NY ------- COST EFFECTIVENESS MATRIX FIGURE B-4 NUB _COF JRA ON 0 A Halliburlon Company RIVER SEDIMENT ALERNATIVES COST L4FARIIR EFFECTIVENESS MEASURES ALTERNATIVES t 1;; z 0 0 ki C.) 2 S d 2 2 I- ‘ I a 0 0 0 s .i U) S z X C.) If:! tI1 F It. 0 urn Z 8 i U) j IL 4w > 0 -J j t J m ?o 5 4 O 0 WLIJ 0 0 U) 2’-4 ‘ I i > ? 1 tL U i Iii U U TYPE OF RATING U) 2 I- 4 0 U WEIGHTINOFACTORS 1.0 1.2 Ø’. 0.6 1.1 1.0 0.6 0.6 0.6 0.6 0.4 9.3.1.8 NO ACTION FOR RIVER SEDIMENTS, ROUTINE DREDGING CONTINUES, WATER SUPPLY IS TREATED INITIAL RATING 1.0 — 1.0 I 2 5 6 4 I WEIGHTED RATING 1.0 1.2 2.2 3.0 4.4 1.0 1.2 3.0 2.5 2.0 0.4 7.5 79 INITIAL RATING WEIGHTED RAT I N 6 . INITIAL RATING WEIGHTED RATING . HUDSON RIVER PCB SIT ,NY ------- COST EFFECTIVENESS MEASURES 1&E I ...... r or U i Ui Z o F 4w w U) z _i > REMNANT DEPOSIT ALTERNATIVES 8 U, I L. iO o U )! w5 c. z I- U) c i 1 .. hi_i 0_i 2 Z 12: 9 4WO _i z z c u 2 9 0 b .U) U) U ___________ ________ I-. O > . ., ... w w z I—o Z U) o x TYPEOF z w ., o a. U, w w ALTERNATIVES RATING ° ° “ ‘ I_i WEIGHTING FACTORS (.0 1.2 0.6 1.1 (.0 0.6 0.6 0.6 0.5 0.4 9.3.1.9 TOTAL REMOVAL OF REMNANT DEPOSITS INITIAL RATING 2.0 1.1 5 5 5 4 5 4 4 5 WEIGHTED RATING 2.0 1.3 3.3 3.0 5.5 6.0 2.4 3.0 2.0 2.0 2.0 24.9 7.5 9.3.1.10 PARTIAL REMOVAL OF REMNANT DEPOSITS INITIAL RATING I . 2 3 3 4 4 4 3 WEIGHTED RATING (.5 (.4 2.9 0 2.2 3.0 (.8 2.4 2.0 2.0 (.2 (7.0 6.1 9.3.1.11 RESTRICTED ACCESS TO REMNANT DEPOSITS INITIAL RATING . 1.0 — (.0 I I ‘ WEIGHTED RATING (.0 (.2 2.2 3.0 1.1 (.0 1.2 0.6 2.5 2.6 0.4 (2.3 6.6 COST EFFECTIVENESS MATRIX FIGURE B-5 HUDSON RIVER PCB SITE, NY ____ ORPIJRATKJN 0 A Halbburt COmpany ------- COST MEARIIR REMNANT DEPOSIT ALTERNATIVES S EFFECTIVENESS MEASURES ALTERNATIVES 0 t z o ° l U z C.) 2 w a. ° . co 4U) 2 1;:; 0 X 2 , o 1.1 UI (I) o j ljI. c ’ 14 )- I- 2 8 ( ‘ 2 ‘ ‘ 4W UI W 0 z ‘ o U) U ) 2 W 8 2 U) U) UI > j () UI I L ‘U TYPEOF RATING WEIGHTING FACTORS I .0 I .2 U) 2 I- 4 0 0 14 0.6 1.1 1.0 0.6 0.6 0.5 0.5 0.4 &3.I. 12 IN-PLACE CONTAINMENT OF REMNANT DEPOSITS INITIAL RATING WEIGHTED RATING 1.1 1.2 2.3 30 33 30 2.4 1.0 2.5 20 1.2 192 8.3 9.3.1.13 IN-SITU DETOXIFICATION OF REMNANT DEPOSITS WITH KOHPEG* INITIAL RATING WEIGHTED RATING 9.31.14 NO ACTION ON REMNANT DEPOSITS WITH RESTRICTED ACCESS TO DEPOSITS 3 AND 5 INITIAL RATING ‘° 1.0 liEu ii iii iii iii liEu IEI lii I WEIGHTED RATING 1.2 2.2 30 II 10 06 06 2.5 2 04 I II.? 5.3 * REMOVED FROM FURThER CONSIDERATION DURING REMEDIAL ALTERNATIVES EVALUATIoN PROCESS ST_EFFECTIVENESS MATRIX HUDSON RIVER PCB SITE, NY FIGURE B-6 NUB _CORPORAT N 0 A Halliburlon Company ------- REMNAMT DEPOSIT ALTERNATIVES 9.3.1.15 PARTIAL REMNANT DEPOSIT REMOVAL /PARTIAL IN-PLACE CONTAINMENT 9.3.1.16 PARTIAL REMNANT DEPOSIT REMOVAL/PARTIAL RESTRICTED ACCESS &3.1 17 PARTIAL REMNANT DEPOSIT IN-PLACE CONTAINMENT/ PARTIAL RESTRICTED ACCESS COST EFFECTIVENESS MATRIX HUDSON RIVER PCB SITE, NY FIGURE 8-7 HINUB _ OR AT N 0 A Halbbui. .. ompany ‘-.1 ------- REMNANT DEPOSIT ALTERNATIVES TYPE OF RATING FACTORS 9.3.118 PARTIAL REMNANT DEPOSIT IN-PLACE CONTAINMENT/PARTIAL IN-SITU DETOXIFICATION * 9.3.1.19 PARTIAL REMNANT DEPOSIT REMOVAL/PARTIAL IN-SITU DETOXIFICATION * IMT IAL RATING WE IGHTED RATING INITIAL RATING WE IGHTED RATING 9.3. 1.20 PARTIAL RESTRICTED ACCESS TO REMNANT DEPOSITS/ PARTIAL IN-SITU DETOXIFICATION* INITIAL RATING FIGURE B-8 H NUB _CCFPORA ON 0 A Halliburlon Company WEIGHTED RATING REMOVED FROM FURTHER CONSIDERATION DURING REMEDIAL ALTERNATIVES COST EFFECTIVENESS MATRIX HUDSON RIVER PCB SITE 1 NY PROCESS ------- APPENDIX C ALTERNATIVE COST ESTIMATES HUDSON RIVER PCBs SITE, NEW YORK ------- The estimated costs used in the matrix evaluation of remedial alternatives are exhibited in Appendix A. The Capital Cost items are presented for each alternative, in order of appearance of alternatives in Chapter 9, on pages C2—C21. Operation and maintenance cost Items are presented on pages 22 through 41. C - i ------- 9.3.1.1 DETOX. OF SEDIMENTS WITH KOEPEG COMPONENT UNITS UNIT COST SUBTOTALS TOTALS MOB/DEMOB CONTAINMENT BASIN OPERATING COST TREATMENT COST TESTING AND MONITORING LANDFILL OF REFUSE HEALTH & SAFETY 0 00 2 ,000 150,000 100 45,000 9,200,000 .25 3,0 00 75,0 00 300,000 145,00 0,’) 00 45,000 9,200 , 000 - 36)337,000 SUBTOTAL 19 OS 6 0,0 00 20% CONTINGENCY 10% OVERHEAD AND PROFIT 15% ENGINEERING 38,]. 9 2,0 00 229,]. 52,000 22.9 1 5 2 00 252.067,2 00 37,8 1 Q 0 80 )TAL CAPITAL COST 289S77,280 1 3 2 ] 4 500 00 1 1 145 ,348D00 C-2 ------- 9.3.1.2 WET AIR OXIDATION OF SEDIMENTS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS SUBTOTAL 1 1 2 1 1452.000 1 25 127 ,0 00,0 00 1 1 10,187,000 3000 75,000 150,0 00 20,000 1 - 5,000 2,00 0,0 00 .066 45,0 00 9 00 ,O00 .25 3000 7 5 ,0 00 30 0,0 00 20,000 1.452,000 5,000 50,000,000 8,382,000 45,000 9200,000 2 46,750 72,02 8 50 20% CONTINGENCY 10% OVERHEAD AND PROFIT 15% ENGINEERING 1440 5 50 86434500 95 , 077 __ - 14261.693 TOTAL CAPITAL COST 109,339.643 MOB/DEMOB CONTAINMENT BASIN OPERATING COST SCREENING OPERATING COST CRUSHING AND SLURRYING OXIDATION UNITS TREATMENT COSTS TESTING AND MONITORING LANDFILL OF REFUSE HEALTH & SAFETY 8 4 3A 50 C-3 ------- 9.3.1.3 INCINERATION OF SEDIMENTS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS IRECT COSTS: 0 KILNS/ANCILLARY UNITS 1 -118,89E .000 118,895,000 RESIDUE DISPOSAL 1 500,000 500,000 MOB/DEMOB 3 .000 3,000 LABOR 0 OPERATING LABOR 2 a736 ,000 17,472000 MAINTENANCE 1 S969 ,750 969 ,750 SUPERVISORY 1 46 8 350 4,68 350 MATERIALS 0 FLOCCULANT 2 116,500 233,000 MAINTENANCE 1 5 96-9 750 5 ,969 .750 UTILITIES 0 ELECTRICITY 2 50 000 1 OQ .000 FUEL OIL 2 1 ,543 00O 3,086.000 SECONDARY WASTE DISPOSAL 2 300D00 60 000 HEALTH & SAFETY 28,133,100 .25 7,033,275 SUBTOTAL 164,550,125 20% CONTINGENCY 32910,025 197,460150 10% OVERHEAD AND PROFIT 19,746,015 217,206,165 15% ENGINEERING 32580,925 TOTAL CAPITAL COST 249,787,090 C-4 ------- SUBTOTALS 1 5,843,000 1 1,740,000 1 426,000 0 3 3,000 8,012,000 2,003,000 9.3.1.4 SECURE LANDFILL DISPOSAL OF SEDIMENTS COMPONENT UNITS UNIT COST SITE CONSTRUCTION 5,843,000 COVER COSTS 1,740,000 SITE MODIFICATIONS AFTER 426,000 CLOSURE MOB/DEMOB 1,000 HEALTH & SAFETY .25 SUBTOTAL 20% CONTINGENCY 10% OVERHEAD AND PROFIT 15% ENGINEERING TOTAL CAPITAL COST TOTA. 10,015,0 00 2,003,000 12,018,000 1201,800 1321 8 00 1,982,970 15,20 2,7 70 C-S ------- 9.3.1.5 DREDGING OF 40 HOT SPOTS OMPONENT UNITS UNIT COST SUBTOTALS TOTALS PREDREDGE SAMPLING DREDGING: THOMPSON ISLAND LOCK #6 LOCK #5 LOCK #4 LOCK #3 LOCK #2 MAT’L REHANDLING SEDIMENT DISPOSAL MOB/DEMOB HEALTH & SAFETY SUBTOTAL 36223 ,500 20% CONTINGENCY 7244700 4346 8,2 00 47 , 81S020 5% ENGINEERING 7 .72,253 TOTAL CAPITAL COST 54 87 ,273 1 1,370,000 1,370,000 0 1 7,204,000 7,204,000 1 838,000 838,000 1 2,800,000 2,800,000 1 1,318,000 1,318,000 1 1,360,000 1,360,000 1 1,446000 1,446,000 1 441,000 441,000 3,452,000 8.4 12,196,800 5 3,000 5 ,000 28,978,800 .25 7,244,700 10% OVERHEAD AND PROFIT 4,346,820 C-6 ------- 9.3.1.6 REDUCED SCALE DREDGING COMPONENT UNITS UNIT COST SUBTOTALS TOTA PREDREDGE SAMPLING 1 1 ,370000 3 ,37Q000 DREDGING: 0 THOMPSON ISLAND 1 7 ,204000 7,204000 LOWER POOL 1 3 ,503 00 3,503,000 MAT’L REHANDLING 1 441000 443,000 SEDIMENT DISPOSAL 645 450 8.4 5,423,780 MOB/DEMOB 4 1 000 000 HEALTH & SAFETY 17,943;780 .25 4485945 SUBTOTAL — — 22 ,429 725 20% CONTINGENCY 4485,945 2 9 1 5.6 70 10% OVERHEAD AND PROFIT 2,691,567 2 6 07,237 15% ENGINEERING 4,441.086 TOTAL CAPITAL COST 34048 23 C-7 ------- 9.3.1.7 NO REMEDIAL ACTION, WATER SUPPLY NOT TREATED TREATABILITY ASSESSMENT 120,000 TOTAL CAPITAL COST 120,000 C-8 ------- 9.3.1.8 NO ACTION, WATER SUPPLY TREATED COMPONENT UNITS UNIT COST SUBTOTALS TOTALS CARBON ADSORPTION TREAT- 1 75,000 75,000 MENT 0 SUBTOTAL 75,000 20% CONTINGENCY 15,000 90,000 10% OVERBEAD AND PROFIT 9,000 9 9,0 00 15% ENGINEERING 14,850 TOTAL CAPITAL COST 113,850 C-9 ------- 9.3.1.9 TOTAL REMOVAL OF ALL REMNANT DEPOSITS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS CONSTRUCT HAUL ROADS 27,000 3 BLOOD CLEAR & GRUB FOR ROADS .9 45 40.5 EXCAVATION 350200 6 2 1 10L200 HAULING 350,200 4 1,400,800 REGRADING 80,650 3 24L950 REVEGETATION 49.8 1000 49,800 NOB/DEMOB 5 1000 5,000 SECURE LANDFILL DISPOSAL 0 OF #1—5 350,200 8.4 2 ,94L680 HEALTH & SAFETY 6,690,630 .25 1472 ,657.5 SUBTOTAL 84 94,128 20% CONTINGENCY 1 98 ,826 10,192,954 10% OVERHEAD AND PROFIT 1 19 ,295 1),,2 12,249 15% ENGINEERING Z681$37 TOTAL CAPITAL COST 12894,086 c-i 0 ------- 4,556,909 911382 546 &2 91 546,829 6 , 015120 902268 6917,? TOTh. SUBTOTALS 1,]. 56,2 00 84000 17,300 2,000 9 770,800 0 1,618,680 907,9 20 9.3.1.10 PARTIAL REMOVAL OF REMNANT DEPOSITS COMPONENT UNITS UNIT COST EXCAVATION OF #3 & 5 192 00 6 REGRADING OF #3 & 5 28 00 3 REVEGETATION OF #3 & 5 17.3 1 ,000 MOB/DEMOB 2 1,000 CLEAR & GRUB FOR ROADS .2 45 HAULING OF #3 & #5 192,700 4 SECURE LANDFILL DISPOSAL OF #3 & 5 192700 8.4 HEALTH & SAFETY 3,63 1.6 80 .25 SUBTOTAL 20% CONTINGENCY 10% OVERHEAD AND PROFIT 15% ENGINEERING TOTAL CAPITAL COST c-Il ------- 9.3.1.11 RESTRICTED ACCESS TO REMNANT DEPOSITS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS IAINLINK FENCE-LANDWARD 12,100 12.5 151 50 MAN GATES 8 250 2000 VEHICLE GATES 8 650 5,200 SIGNS 257 75 19275 REVEGETATION 49.8 1000 49,800 MOB/DENOB 5 1000 5,000 HEALTH & SAFETY 49 800 .25 12,450 St}BTOTAL 244 ,975 20% CONTINGENCY 48,995 29 3S 70 10% OVERHEAD AND PROFIT 29,397 323367 15% ENGINEERING 48505 TOTAL CAPI TAL COST 3714872 C-i 2 ------- 9.3.1.12 IN-PLACE CONTAINMENT OF REMNANT DEPOSITS COMPONENT UNITS UNIT COST SUBTOTALS ‘TA SUBTOTAL 35,000 93,000 30,300 7,000 7,000 37 0.9 5 1, 140 , 700 3 7 9 22 3 1,000 45 1,000 0.25 105,000 651,000 272,700 154,000 21,000 37,000 40.5 5,000 285,175 1,530,9 20% CONTINGENCY 10% OVERHEAD AND PROFIT 15% ENGINEERING TOTAL CAPITAL COST 306,1 1,837,0 CONSTRUCT HAUL ROADS SUBSOIL (1.5 FT THICK) TOPSOIL (0.5 FT THICK) RIP-RAPOF 2&4 REGRADING OF 2 & 4 REVEGATATION CLEAR & GRUB FOR ROADS MOB/DEMOB HEALTH & SAFETY 183,7 2,020,8 303,1. 2,323,9 C- 3 ------- 5 350,000 200 27 , 000 49.8 .9 3 5 ,0 8 4$ 00 SUBTOTALS 5,000 35,00 0 ,0 00 30,000 81,000 49 00 40.5 8,771200 9.3.1.13 IN-SITU DETOXIFICATION OF REMNANT DEPOSITS OMPONENT UNITS UNIT COST MOB/DEMOB 1,000 TREATMENT 100 TESTING & MONITORING 150 ACCESS ROADS 3 REVEGETATION 1 ,000 CLEAR & GRUB ROADS 45 HEALTH & SAFETY .25 SUBTOTAL 20% CONTINGENCY TOTALS 43 $37,041 887,408 52724 449 5272445 57 $9 6 8 93 8 99,534 66 96427 10% OVERHEAD AND PROFIT 15% ENGINEERING TOTAL CAPITAL COST C- 4 ------- 9.3.1.14 NO ACTION ON #1,2 & 4/RESTRICT ACCESS TO #3 & 5 COMPONENT UNITS UNIT COST SUBTOTALS TO’I CHAINLINX FENCE-LANDWARD 0 ON #3 & 5 5,300 12.5 66,250 MAN GATES 4 250 1,000 VEHICLE GATES 4 650 2,600 SIGNS 100 75 7,500 REVEGETATION ON #3 & 5 17.3 1)000 17,300 MOB/DENOB 2 ])000 2,000 HEALTH & SAFETY 19,300 .25 4,825 SUBTOTAL 10J ,475 20% CONTINGENCY 20,295 121.7 70 10% OVERHEAD AND PROFIT 12 .177 133.947 15% ENGINEERING 20 92 TOTAL CAPITAL COST 154p39 C-is ------- .3.1.15 PARTIAL REMOVAL/CONTAINMENT OF REMNANT DEPOSITS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS 20% CONTINGENCY 15% ENGINEERING TOTAL CAPITAL COST 1,187,103 7,1.22,6 19 7,834,880 1,175,232 9,010,113 CONSTRUCT HAUL ROADS 27,000 3 81,00-0 EXCAVATION OF #3 & 5 192,700 6 . 1,156,200 REGRADING OF #1, 2 & 4 11700 3 35,100 REVEGETATION OF #1—5 49.8 1000 49,800 MOB/DENOB 5 1000 5,000 SUBSOIL ON #1,2 & 4 79,000 7 55 000 TOPSOIL ON #1,2 & 4 26,400 9 237,600 RIP—RAP #1,2 & 4 11,700 22 257,400 CLEAR & GRUB FOR ROADS .9 45 40.5 HAULING 192700 4 770,800 DISPOSAL (SECURE LANDFILL) 0 OF #3 & 5 192,700 8.4 1,618,680 HEALTH & SAFETY 4,68 3 5 80 .25 1.17-0,895 SUBTOTAL ‘0 % OVERHEAD AND PROFIT 5,935,516 7]. 2,2 62 C-i 6 ------- 9.3.1.16 PARTIAL REMOVAL/RESTRICTED ACCESS OF REMNANT DEPOSITS COMPONENT UNITS UNIT COST SUBTOTALS TOT EXCAVATION 192 00 6 1,156,200 REGR.ADING OF #3 & 5 28 00 3 84,000 REVEGETATION OF #1-5 49.8 3,000 49,800 CHAINLINK FENCE-LANDWARD 6$00 12.5 85,000 MAN GATES 4 250 1,000 VEHICLE GATES 4 650 2,600 SIGNS 157 75 11,775 MOB/DEMOB 5 3,000 5,000 HAULING OF #3 & 5 192,700 4 770,800 CLEAR & GRUB ROADS .2 45 9 DISPOSAL OF #3 & 5 192,700 8.4 3,618,680 HEALTH & SAFETY 1684480 .25 921,120 SUBTO AL 4,705,984 20% CONTINGENCY 941,197 5,647,181 10% OVERHEAD AND PROFIT 564,718 6213,899 15%ENGINEERING 93] -’ c TOTAL CAPITAL COST 7 .43 ,6 4 C-i 7 ------- 9.3.1.17 PARTIAL CONTAINMENT/RESTRICTED ACCESS OF REMNANT DEPOSITS OMPONENT UNITS UNIT COST SUBTOTALS TOTALS SUBSOIL (1.5 FT THICK) 42,000 7 294,000 TOPSOIL (0.5 FT THICK) 14 ,000 9 126,000 REVEGETATION 49.8 1,000 49,800 CHAINLINK FENCE-LANDWARD 6,800 12.5 85,000 MAN GATES 4 250 1,000 VEHICLE GATES 4 650 2,600 SIGNS 157 75 11,775 MOB/DEMOB 5 1,000 5,000 CLEAR & GRUB FOR ROADS .2 45 9 HEALTH & SAFETY 474,800 .25 118,700 SUBTOTAL 693,884 20% CONTINGENCY 13 777 83Z66]. 10% OVERHEAD AND PROFIT 8 266 91 E 9 27 15% ENGINEERING 137,389 ‘ OTAL CAPITAL COST 105 316 C- 18 ------- 9.3.1.18 PARTIAL CONTAINMENT/IN-SITU DETOX OF REMNANT DEPOSITS COMPONENT UNITS UNIT COST SUBTOTALS 20% CONTINGENCY 15% ENGINEERING TOTAL CAPITAL COST 3 V 3 8 49 3,07 3,3 85 33,807,233 5,071, . j 38,878.318 CONSTRUCT HAUL ROADS 27,000 3 81 ,000 SUBSOIL FOR #1,2 &4 79,000 7 553,000 TOPSOIL FOR #1, 2 & 4 26,400 9 237,600 RIP-RAP OF *1, 2 & 4 11,700 22 257,400 REGRADING OF #1,2 & 4 11,700 3 35,100 REVEGETATION 49.8 1,000 49,800 MOB/DEMOB 5 1,000 5,000 CLEAR & GRUB FOR ROADS 0 TO #2, 3 & 4 .9 45 40.5 DETOXIFICATION WI KORPEG 192700 100 19, 70,000 TESTING & MONITORING 110 150 16,500 HEALTH & SAFETY 20,424400 .25 5,106,100 SUBTOTAL 10% OVERHEAD AND PROFIT 25,611,541 5,122,308 C-i 9 ------- 9.3.1.19 PARTIAL REMOVAL/IN-SITU DETOXIFICATION OF REMNANT DEPOSITS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS CONSTRUCT HAUL ROADS 27.000 3 81,000 EXCAVATION 157500 6 945,000 REGRADING OF 1, 2 & 4 52700 3 158.100 REVEGETATION 49.8 1,000 49200 MOB/DEIIOB 5 1,000 5,000 CLEAR & GRUB FOR ROADS .9 45 40.5 HAULING OF #1, 2 & 4 15:7,500 4 63Q.000 DISPOSAL (SECURE LANDFILL) 0 OF *1, 2 & 4 1 7 ,500 8.4 1,323,000 DETOXIFICATION WI KOHPEG 192,700 10’O 19,270,000 TESTING & MONITORING 110 150 16,500 HEALTH & SAFETY 22,397,400 .25 5,599,350 SUBTOTAL 20% CONTINGENCY 0% OVERHEAD AND PROFIT 15% ENGINEERING TOTAL CAPITAL COST 28.077,791 5,615,558 33,693,349 3,369 35 37,062 83 5,559 403 42,622,086 C-20 ------- 4 157 49.8 5 .2 192,700 110 19,341,300 REMNANT DEPOSITS COST SUBTOTALS 12.5 85,000 250 1,000 650 2.600 75 11,775 1000 49,800 1000 5,000 45 9 100 19,270,000 150 16,500 .25 4,835,325 9.3.1.20 PARTIAL DETOX/RESTRICTED ACCESS OF COMPONENT UNITS UNIT CHAINLINK FENCE-LANDWARD 6,800 NAN GATES 4 VEHICLE GATES SIGNS REVEGETATION OF #1-5 MOB /DENOB CLEAR & GRUB FOR ROADS DETOXIFICATION W/ KOHPEG TESTING & MONITORING HEALTH & SAFETY SUBTOTAL 20% CONTINGENCY TOTALS 24,277,009 4,855,402 29,3.32,411 2,913,241 32,045,652 4,806 36,852,500 10% OVERHEAD AND PROFIT 15% ENGINEERING TOTAL CAPITAL COST C-2I ------- .3.1.1 DETOX. OF SEDIMENTS WITH KOEPEG COMPONENT UNITS UNIT COST SUBTOTALS TOTALS NO O&M COSTS 0 TOTAL ANNUAL COST (20 YEAR PERIOD) 0 PRESENT WORTH (10% DISCOUNT RATE) 0 20% CONTINGENCY 0 TOTAL OPERATION AND MAINTENANCE COST 0 C-22 ------- 9.3.1.2 WET AIR OXIDATION OF SEDIMENTS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS NO O&M COSTS 0 TOTAL ANNUAL COST (20 YEAR PERIOD) 0 PRESENT WORTH (10% DISCOUNT RATE) 0 20% CONTINGENCY 0 TOTAL OPERATION AND MAINTENANCE COST 0 C 23 ------- .3.1.3 INCINERATION OF SEDIMENTS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS NO O&M COSTS 0 TOTAL ANNUAL COST (20 YEAR PERIOD) 0 PRESENT WORTH (10% DISCOUNT RATE) 0 20% CONTINGENCY 0 TOTAL OPERATION AND MAINTENANCE COST 0 C -24 ------- COMPONENT S.T. LEACEATE MONITORING: SAMPLING TESTING AIR MONITORING: SAMPLING TESTING VEGETATION MONITORING: SAMPLING TESTING TOTAL ANNUAL COST (2 YEAR PERIOD) PRESENT WORTH (10% DISCOUNT RATE) SUBTOTALS 0 210,000 374400 0 72,000 81,250 0 30 00 600 TOTAL PRESENT WORTH 20% CONTINGENCY TOTAL OPERATION AND MAINTENANCE COST 286,056 1,286,467 1,572.523 31 4 5 05 1887,027 9.3.1.4 SECURE LANDFILL DISPOSAL OF SEDIMENTS COMPONENT UNITS UNIT COST GROUNDWATER MONITORING: SAMPLING 1 16,000 TESTING 64 200 LEACHATE MONITORING: SAMPLING 1 2,000 TESTING 4 200 INSPECTIONS 2 1 000 TOTAL ANNUAL COST (20 YEAR PERIOD) PRESENT WORTH (10% DISCOUNT RATE) UNITS UNIT COST SUBTOTALS 0 16,000 12800 0 2000 800 2000 TOL 33,600 286,056 TOTALS 741,250 1286467 1 936 1 650 1 4 2]. 0 0 00 400 72,000 125 3,000 150 C-25 ------- .3.1.5 DREDGING OF 40 HOT SPOTS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS FISH MONITORING: 0 COLLECTION 1 63,000 63,000 ANALYSIS 1 70.000 70,000 LABOR 8 Th28 6L024 RAW WATER SAMPLING 0 & TESTING 1 110,000 110,000 WATER SUPPLY MONITORING: 0 SAMPLING 1 5,000 000 TESTING 24 150 3400 DREDGE SPOIL MONITORING: 0 SAMPLING 1 16,000 16,000 TESTING 50 150 7,500 TOTAL ANNUAL COST (20 YEAR PERIOD) 336,124 PRESENT WORTH (10% DISCOUNT RATE) 2,861613 20% CONTINGENCY 572323 MONITORING OF SECURE LANDFILL DISPOSAL 1887 27 3TAL OPERATION AND MAINTENANCE COST 5320863 C-26 ------- 9.3.1.6 REDUCED SCALE DREDGING COMPONENT UNITS UNIT COST SUBTOTALS TOTALS FISH MONITORING: 0 COLLECTION 1 63,000 63,000 ANALYSIS 1 70,000 74000 LABOR 8 7,628 6 024 RAW WATER SAMPLING 0 & TESTING 1 110,000 110,000 WATER SUPPLY MONITORING: 0 SAMPLING 1 5000 5000 TESTING 24 150 1600 DREDGE SPOIL MONITORING: 0 SAMPLING 1 16.000 16 000 TESTING 50 150 7,500 TOTAL ANNUAL COST (20 YEAR PERIOD) 336.124 PRESENT.WORTH (10% DISCOUNT RATE) 2.86L613 20% CONTINGENCY 572.323 MONITORING OF SECURE LANDFILL DISPOSAL ] ,887I TOTAL OPERATION AND MAINTENANCE COST 5 ,320963 C-27 ------- 9.3.1.7 NO ACTION FOR SEDS., ROUTINE DREDGING, WATER NOT TREATED . .DMPONENT UNITS UNIT COST SUBTOTALS TOTALS FISH MONITORING: 0 COLLECTION 1 63 ,000 6 ,0O0 ANALYSIS 1 7O 00O 70,000 LABOR 8 7,628 6] O24 RAW WATER SAMPLING 0 & TESTING 1 110,000 110,000 WATER SUPPLY MONITORING: 0 SAMPLING 1 5,000 5,000 TESTING 24 150 3,600 DREDGE SPOIL MONITORING: 0 SAMPLING 1. 16 000 16,000 TESTING 50 150 7,500 TOTAL ANNUAL COST (20 YEAR PERIOD) 336,124 PRESENT WORTH (10% DISCOUNT RATE) 2,86]4613 20% CONTINGENCY 572,323 TOTAL OPERATION AND MAINTENANCE COST 3 ,43 936 C-28 ------- 9.3.1.8 NO ACTION FOR SEDS., ROUTINE DREDGING, WATER SUPPLY TREATED COMPONENT UNITS UNIT COST SUBTOTALS TOTALS FISH MONITORING: 0 COLLECTION 1 63 000 6 000 ANALYSIS 1 70,000 70,000 LABOR 8 7,628 61,024 RAW WATER SAMPLING 0 & TESTING 1 110,000 110,000 WATER SUPPLY MONITORING: 0 SAMPLING 1 5 000 5,000 TESTING 24 150 3,600 DREDGE SPOIL MONITORING: 0 SAMPLING 1 16,000 16000 TESTING 50 150 7,500 TOTAL ANNUAL COST (20 YEAR PERIOD) 336,124 PRESENT WORTH (10% DISCOUNT RATE) 286] 613 COMPONENT UNITS UNIT COST SUBTOTALS TOTALS CARBON CHANGEOUT 1 81000 83,000 PERIODIC COST, 4 YEAR INTERVAL (20 YEAR PERIOD) 81000 PRESENT WORTH (10% DISCOUNT RATE) 152.257 2.861,613 152.257 TOTAL PRESENT WORTH 3,013,870 20% CONTINGENCY 602,774 TOTAL OPERATION AND MAINTENANCE COST 3,616,644 C-29 ------- 9.3.1.9 TOTAL REMOVAL OF REMNANT DEPOSITS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS ONITORING OF SECURE LANDFILL DISPOSAL 1 ,8B7,O27 1 887,O27 TOTAL OPERATION AND MAINTENANCE COST 1 ,887 ,027 C-30 ------- 9.3.1.10 PARTIAL REMOVAL OF REMNANT DEPOSITS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS MONITORING OF RIVER 1 11Q 000 110,000 ANNUAL COST (20 YEAR PERIOD) 110.000 PRESENT WORTH (10% DISCOUNT RATE) 936,492 20% CONTINGENCY 187.298 MONITORING OF SECURE LANDFILL DISPOSAL 1.887,027 TOTAL OPERATI ON AND MAINTENANCE COST 3,01 0.8 17 C3 1 ------- 9.3.1.11 RESTRICTED ACCESS TO REMNANT DEPOSITS )MPONENT UNITS UNIT COST SUBTOTALS TOTALS MONITORING OF RIVER 1 110,000 110,000 TOTAL ANNUAL COST (20 YEAR PERIOD) 110,000 PRESENT WORTH (10% DISCOUNT RATE) 936,492 20% CONTINGENCY 187,298 TOTAL OPERATION AND MAINTENA}ICE COST 1 ,123790 C-32 ------- 9.3.1.12 IN-PLACE CONTAINMENT OF REMNANT DEPOSITS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS MONITORING OF RIVER 1 110,000 110,000 TOTAL ANNUAL COST (20 YEAR PERIOD) 110,000 PRESENT WORTH (10% DISCOUNT RATE) 936A92 20% CONTINGENCY 187,298 TOTAL OPERATION AND MAINTENANCE COST 1,123,790 C-33 ------- .3.1.13 IN-SITU DETOXIFICATION OF REMNANT DEPOSITS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS NO O&M COSTS 0 TOTAL ANNUAL COST (20 YEAR PERIOD) 0 PRESENT WORTH (10% DISCOUNT RATE) 0 20% CONTINGENCY 0 TOTAL OPERATION AND MAINTENANCE COST 0 C-34 ------- 9.3.1.14 NO ACTION ON #1,2 & 4/RESTRICT ACCESS TO #3 & 5 COMPONENT UNITS UNIT COST SUBTOTALS TOTA l MONITORING OF RIVER 1 110000 110000 TOTAL ANNUAL COST (20 YEAR PERIOD) 110000 PRESENT WORTH (10% DISCOUNT RATE) 936492 20% -CONTINGENCY 187298 TOTAL OPERATION AND MAINTENANCE COST 1123790 C-35 ------- 9.3.1.15 PARTIAL REMNANT DEPOSIT REMOVAL/IN-PLACE COMPONENT UNITS UNIT COST ONITORING OF RIVER 1 110,000 ANNUAL COST (20 YEAR PERIOD) PRESENT WORTE (10% DISCOUNT RATE) 20% CONTINGENCY MONITORING OF SECURE LANDFILL DISPOSAL TOTAL OPERATION AND MAINTENANCE COST CONTAINMENT SUBTOTALS 110,000 TOTALS 11 0 0 00 93 6,492 187298 1,8 87,027 3,010,817 C-36 ------- 9 .3.1.16 PARTIAL REMNANT DEPOSIT REMOVAL/RESTRICTED ACCESS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS MONITORING OF RIVER 1 110,000 110 D00 ANNUAL COST (20 YEAR PERIOD) 110,000 PRESENT WORTh (10% DISCOUNT RATE) 936,492 20% CONTINGENCY 187,298 MONITORING OF SECURE LANDFILL DISPOSAL ] 887,027 TOTAL OPERATION AND MAINTENANCE COST 3,010,817 C-37 ------- 9.3.1.17 PARTIAL REMNANT IN-PLACE CONTAINMENT/RESTRICTED ACCESS COMPONENT UNITS UNIT COST SUBTOTALS iONITORING OF RIVER 1 11Q,000 110,000 TOTAL A1 T UAL COST (20 YEAR PERIOD) PRESENT WORTH (10% DISCOUNT RATE) 20% CONTINGENCY TOTAL OPERATION AND MAINTENANCE COST TOTALS 1]. 0 0 00 93 64 92 187,2 98 ] 12 3,7 90 C-38 ------- 9.3.1.18 PARTIAL REMNANT IN-PLACE CONTAINMENT/IN-SITU DETOXIFICATION COMPONENT UNITS UNIT COST SUBTOTALS TOTALS MONITORING OF RIVER 1 11 000 11OP OO TOTAL ANNUAL COST (20 YEAR PERIOD) 110,000 PRESENT WORTH (10% DISCOUNT ATE) 936,492 20% CONTINGENCY 187,298 TOTAL OPERATION AND MAINTENANCE COST ],123,790 C-39 ------- 9.3.1.19 PARTIAL REMOVAL OF REMNANT DEPOSITS/IN-SITU DETOXIFICATION .)MPONENT UNITS UNIT COST SUBTOTALS TOTALS MONITORING OF SECURE LANDFILL DISPOSAL 1 1,887,027 — 1,887,027 TOTAL OPERATION AND MAINTENANCE COST ]. ,887 027 C-40 ------- 9.3.1.20 PARTIAL IN-SITU DETOX. OF REMNANT DEPOSITS/RESTRICTED ACCESS COMPONENT UNITS UNIT COST SUBTOTALS TOTALS MONITORING OF RIVER 1 110,000 110,000 TOTAL ANNUAL COST (20 YEAR PERIOD) 110 1000 PRESENT WORTH (10% DISCOUNT RATE) 936492 20% CONTINGENCY 187,298 TOTAL OPERATION AND MAINTENANCE COST ],123,790 C-41 ------- APPENDIX D PHASE II. REMEDIAL INVESTIGATION OF THE HUDSON RIVER ------- APPENDIX D PHASE II. REMEDIAL INVESTIGATION OF ThE HUDSON RIVER The following are two Remedial Investigation tasks scheduled to proceed in Phase II of the Remedial Investigation of the Hudson River. Phase II will proceed only if It is determined from the results of Phase I that PCB contamination of the sediments pose a significant health threat to area residents and that further remedial action will be required. The alternatives presented here are only suggested alternatives, arid It may be determined later that additions or deletions will be required. D.1 Sediment Sampling Survey Present Sampling Efforts The present information on the distribution of PCB—contaminated bed sediments stems from NYSDEC surveys completed in 1977 through 1978. These surveys consisted of 1200 core and grab samples (approximately 700 of which were analyzed for PCB5) distributed over 40 miles of river. The only recent results come from an EPA—sponsored survey consisting of core samples from 66 stations which duplicated approximately 45 earlier NYSDEC sampling locations. This survey was conducted in August 1983. PrelIminary results of the August survey indicate that, in some areas, the older data are still reliable, while in other areas the distributions of PCB—contaminated sediments have changed. There are a number of important questions which must be answered by additional samplipg before efficient planning can take place. Description The proposed comprehensive sampling program will have the following objectives: • Validating the PCB hot—spot theory. This objective will investigate questions such as: D- 1 ------- — Do continuous areas of highly contaminated sediments actually exist? — Are contaminated sediments confined to localized packets, but clustered in a way that, in effect, simulates continuous areas of high contamination? — Are contaminated sediments confined to localized pockets and distributed in a manner that makes remedial actions infeasible? — If contaminated sediments actually do exist as localized pockets, what is the probability that a large number of these have been missed by sampling? • The distribution of contaminated sediment deposits suitable for remedial actions. This objective would assume a PCB action level of 50 g/g and investigate better methods of sampling and mapping, leading to the accurate delineation of contaminated sediments. • The total error involved with sampling, analytical, and mapping procedures. This objective would result in the expression of a confidence level or interval which would be used in critical evaluations of PCB mass estimates, hot spot delineations, and remedial designs. • Correlations between PCB contamination and stream channel or sediment characteristics. This objective Is essential for a strong conceptual understanding which would be invaluable for further work in the Hudson River and in other contaminated waterways. • The mobility status of the features which are being sampled. This objective refers to the determination of the likelihood of scour or deposition at the area of interest. This type of information will be used to generate estimates of the time period over which the data is valid, how soon remedial actions should be completed, or to what extent PCB— contaminated deposits can be left alone. D-2 ------- To efficiently meet the objectives specified above, the proposed plan will be carried out in two stages. Stage I will concentrate a large number of samples In previously delineated hot spots representing the following conditions: • Upstream hot spots • Downstream hot spots • Large hot spots covering bank and channel areas • Small localized hot spots The study will investigate the variation of PCBs with distance from the center of contamination, with depth in the sediment, and with other parameters, including sediment characteristics, channel characteristics, and other toxic materials. Studies in these areas will be described in detail in other sections. Bed—load movement to and from selected areas will also be measured. Strengthened relationships or lack of relationships developed from Stage I studies will dictate the procedures In Stage Ii. The second stage will essentially be a comprehensive survey of the sediments in the Upper Hudson River from the Glens Falls area to Albany. This stage will address the accurate delineation of contaminated sediments, and estimation of PCB amounts located in these areas. Methods Stage I will consist of obtaining relatively undisturbed sample cores, at least 3 feet In length, from locations specified by 100—foot sampling grids Imposed on the selected hot spots. The sampling grids will extend past the present hot—spot boundaries to include cold areas. All sample stations will be required to have accurate and precise locations assigned to them; however, it will not be necessary to prelocate the sample station exactly on the intersections. The proposed sample location can Initially be estimated from maps but it will be necessary to get an accurate position on the station once the core is retrieved. This is easily done with electronic survey equipment. Base—line survey information Is adequate in the Thompson island pool area; however, base—lines may have to be surveyed in lower pools. D-3 ------- Hot spots 6, 14, 20, 28, and 35 are tentatively selected for the Stage I study. Approximately 275 sample stations will be required to cover this area in detail. Each 3—foot core will be subsampled according to its morphologic layers. Approximately 3 to 4 subsamples each may be expected. Half of the cores from each study area will be analyzed for particle size class and organic content, and selected samples will be analyzed for priority pollutants. Other data which will be recorded include river stage, depth to sample, and flow velocities. Bed load transport studies (described in another section) will also be clone in selected areas. The analysis and quantification of PCBs is subject to a great deal of misinterpretation. Therefore every effort will be made to acquire the most highly qualified contractor using the most accurate and up—to—date analytical methods. The exact Aroclors to be analyzed and the method for reporting total PCBs will be specified. Appropriate field duplicates, spikes, and blanks will be specified. To ensure comparability, analytical methods will not be modified for the duration of the study. To handle the great amounts of information generated in the study and to aid data analysis, a computerized data base management system will be used, which will be compatable with appropriate mapping and statistical software. Each data point will be screened for quality and authenticity to ensure that only quality data will be used In later analyses. Bed—load Transport Studies Present Sampling Efforts Cursory measurements of bed—load transport were made by Rensselaer Polytechnic Institute in 1977. This information; however, Is not sufficient for interpreting local patterns of deposition and scour. Presently, only suspended sediment transport Is being measured. Bed—load transport is an important factor controlling the micro— relief of the river bottom surface. In a low—velocity river such as the Hudson. this D-4 ------- process may have a large Influence on the distribution and movement of PCB— contaminated sediment. Description Bed—load transport will be measured across the river above and below selected hot spot areas studied in Stage I of the bed sediment survey. Bed—load transport will also be measured In the Champlain Canal above Lock 6. The canal location is important because substantial amounts of contaminated sediments, helped along by large traffic and lock operation, could move through Lock 6 to lower reaches of the river. Transport rates will be measured at each location at low, medium, and high flows. Channel cross—section measurements and a full range of flow measurements will be made so that measured bed—load transport can be compared with estimates calculated from various bed—load transport formula. Analysis of bed—load transport data will reveal the dynamics of the river in critical areas and aid in the evaluation of the stability of hot spots and the likelihood that contaminated deposits will either be buried or exposed. Methods Structure—type sediment traps with sliding, water—tight lids, which are inserted into the sediment so that the trap openings are even with the surface of the bed, will be used. Two rows of traps will be installed across the river at each test reach. It should be possible to use digging frames to install all traps; however, divers may be needed .to place traps In deeper water. If operation of these traps becomes problematical, then simpler but less efficient pan type or pressure difference type samplers will be used. Bed—load samples will be collected for an extended period of time during low, medium, and high flow periods. The flow velocity profile, depth, mean channel slope, and water temperature will be recorded to facilitate the calibration of the bed—load functions which will be used. Suspended—sediment transport measurement above the transects is also desirable. D-5 ------- APPENDIX E ANALYSIS OF 1983 SAMPUNG DATA ------- APPENDIX E ANALYSIS OF 1983 SAMPUNG DATA In August 1983 Upper Hudson River sediments were resampled at selected locations to update the 1977—1978 sediment data. Fifty—four core samples and twelve grab samples were recovered from 66 locations along a 9—mile stretch of river between Rogers Island and a point approximately 1/2 mile south of Lock 6. Sample station locations in 1983 were surveyed in and plotted on 1:4200 planimetric maps courtesy of NYSDEC. Plotted sampling locatlons are provided in Attachment 1. Core samples were subdivided according to visible strata, and each subsection was sampled for PCB analysis. PCB analytical procedures similar to those used for the NYSDEC survey were used to maximize comparability. Sample preparation procedures and analytical methods are outlined In Attachment 2. A summary of the 1983 sampling results is presented in Table E—1. Only depth— weighted average PCB concentrations and maximum PCB values are reported. Forty—two of the sixty—five samples were located on or within the boundaries of PCB hot spots that were delineated on maps received from NYSDEC. A total of 15 hot spots were sampléo. The arithmetic mean PCB concentration of hot spot samples was 52.6 ppm. The corresponding mean for the 24 samples from cold areas was 13.3 ppm. Fifteen of forty—two samples taken from PCB hot spots contained concentrations greater .than 50 ppm in some part of the core, and twelve cores showed depth— weighted averages greater than 50 ppm. Two cores taken from cold areas below Griffin Island had depth—weighted averages that exceeded 50 ppm. The depth of maximum concentration within the cores was equally distributed between surface and deeper layers, but the more highly contaminated sediments E 1 ------- TABLE E-1 1983 SAMPUNG RESULTS HUDSON RIVER PCB SITE. NEW YORK Sample N urn b or Location Depth—Weighted Average PCB Concentration (ppm) Total Depth (inches) High Concentration (ppm) Depth Interval of High Concentration (inches) 1 3 4 5 6 7 BA 9 10 11 12 13 14 15 15A 16 17 18 19 21 22 23 25 26 Hot Spot 2 Border Line, Hot Spot 6 Hot Spot 4 Hot Spot 5 Hot Spot 5 Hot Spot 5 Hot Spot 6 Hot Spot 6 Hot Spot 6 Hot Spot 6 Hot Spot 6 Border Line, Hot Spot 6 Hot Spot 6 Hot Spot 8 Hot Spot 8 Hot Spot 8 Border Line. Hot Spot 9 5.8 7.7 2.6 13.8 29.9 ND 39.8 6.7 58.6 11.0 21.6 5.0 9.0 24.6 7.9 41.0 55.0 240.0 3.3 255.0 3.2 8.2 89.1 14 12 22 15 22 Grab Sample 20 Grab Sample 16 Grab Sample Grab Sample 15 B Grab Sample 8 Grab Sample Grab Sample 33 7 18 Grab Sample 10 13 11.0 13.0 6.0 65.0 36.4 120.0 71.2 5.0 12.0 9.0 683.0 3.5 307.0 11.3 110.0 0—7 6 — 12 15 — 22 0-3 5 — 14 0-3 0-4 4-8 15 — 23 0-4 0-9 5 - 10 3 - 13 1 0-5 4 — 16 25.1 18 24.8 0-3 ------- TABLE E-1 1983 SAMPUNG RESULTS HUDSON RIVER PCB SITE. NEW YORK PAGE TWO Sample Number Location Depth-weighted Av rage PCB Concentration (ppm) Total Depth (inches) High Concentration (ppm) Depth Interval of High Concentration (inches) 26A 27 28 28A 29 30 32 (1) 33 34A 36 37 38 39 40 419 42B 43B 44 44B 45B 46B 47A 48 49 Border Lines Hot Spot 8 Hot Spot 14 Hot Spot 14 Hot Spot 16 Border Line, Hot Spot 16 Hot Spot 16 Border Line, Hot Spot 17 Hot Spot 18 8.9 3.9 35.5 23.7 433.0 28.6 3.1 12.8 58.8 11.9 11.7 0.3 7.6 25.0 4.0 9.0 135.0 9.0 87.0 161 .0 17.8 1.0 4.0 41.0 167.0 28 9 6 15 7 12 10 14 20 Grab Sample 9 14 9 9 Grab Sample 29 20 7 12 13 16 9 5 15 15 8.0 3.9 54.6 29.1 641.0 65.3 3.1 20.9 125.0 22.2 7.6 25.0 9.0 240.0 9.0 7.0 200.0 31.0 2.0 0.0 41.0 210.0 0 — 12 3—9 3—6 3 — 15 3—7 4—7 0—4 5 - 10 8 — 17 0—3 0—3 0—9 0—3 3—4 0-3 0—6 3 — 13 4—8 0—3 0—2 0 - 15 7 — 15 Hot Hot Hot Hot Hot Hot Hot Hot Spot 10 Spot 10 Spot 10 Spot 11 Spot 12 Spot 14 Spot 14 Spot 14 ------- TABLE E-1 1983 SAMPLING RESULTS HUDSON RIVER PCB SITE, NEW YORK PAGE ThREE Sample Number Location Depth-weighted Average PCB Concentration (ppm) Total Depth (Inches) High Concentration (ppm) Depth Interval of High Concentration (inches) 519 52 54 55 57 59 63 r 64 65 66 70 71 P—3--15—l P—3-15-2 P—3—15-3 P—3—15-4 P—3-15-5 Depth-weighted Average (C 1 d 1 )/D 0.9 0.7 4.0 4.0 1.0 86.6 3.9 58.7 1.9 25.7 4.8 15 Grab Sample 17 10 Grab Sample 10 11 16 21 20 13 0.9 4.0 4.0 90.0 4.0 130.0 6.1 27.8 6.0 0-3 0—3 0—3 2 — 11 0-3 3—6 2—7 3 - 20 4 - 13 where C 1 = concentration of layer I di = length of layer I D total depth Layers where PCB was Identified be’ow detection limit were assigned a concentration equal to the concentration of the next least contaminated layer. Hot Spot 20 Hot Spot 28 Hot Spot 28 Hot Hot Hot Hot Hot Hot Spot 15 Spot 18 Spot 18 Spot 18 Spot 18 Spot 18 11.0 0.6 4.4 1.0 3.3 2.0 22 17 35 18 27 15 11.0 0.6 4.4 1.0 10.6 5.1 0—5 0—3 0—3 0—3 0-3 0-3 ND — Not Detected ------- were usually found deeper than 3 inches in depth. The core samples averaged 15 inches long. An arbitrary distance of 100 feet was set as the limit over which 1983 and older data could be compared. Overall, there were 62 NYSDEC survey points within a 100—foot radius of 1983 sample stations. Comparisons ‘were made strictly on a depth—related basis. For example, PCB values from grab samples were compared only with the results from the first 3 inches of a core, and different length cores would be compared only when depth—weighted averages could be computed for depths comparable within plus or minus 5 inches. Most of the older data used In the comparisons were from grab samples. The new data were compared to 1977—1978 data for locations within -both 50 and 100 feet of the new sample locations, and then were plotted on log—log plots. These plots are presented in Figures E—1 and E—2. Since both surveys were theoretically sampling the same population, on the average, there should be a one to one correspondence between the data sets, and a line of slope 1.0 should fit the points on a log—log plot Practically speaking, a perfect fit would be unrealistic because of the naturally high variability of PçB—contaminated sediment deposits and the low number of comparisons which are available. There is some correlation between the two data sets Indicating that in 1983, the higher concentrations are generally found where high concentrations were found in 1977—78. ThIs relationship is reflected In the cold— and hot—spot means reported above. The spread of the data, however, on the log—log plots indicates that real PCB concentration values may differ by up to 1 or 2 orders of magnitude within 100 feet. Also, In 53 cases, the values from the 1977—1978 sutvey are substantially higher than PCB values from the 1983 survey. Only 9 of the 62 comparisons In 1983 showed higher results In 1983 than in 1977—1978. Such a bias in the data could be caused by many mechanisms. Differences in the analysis and quantification of PCB Aroclors and the method of expressing total E—5 ------- 3— . 2- S 0 . 4 z S U i z S 0 C.) C.) . 0 S 2 . S S 0 V.. I .1 0 I 2 3 LOG 10 ( PCB CONCENTRATION 1977- 1978 ) FIGURE E-I ALL POSSIBLE COMPARISONS WIThIN A 50’ RADIUS; 977-1978 vs. 1983 SEDIMENT DATA - F±I IP4JL.JS HUDSON RIVER PCB SITE, HUDSON RIVER, NY Il I- N 0 A Hailiburton Company E—6 ------- 3— 2- . C , 0 S z 0 I- z • S z - o - S C .) S 0 C .) S 0 Q S •S C, o S . 0- I - p I 2 3 4 0 LOG ( PCB CONCENTRA11ON 977-1978) ALL POSSiBLE COMPARISONS WITHIN A 1001 ____ RADIUS; 1977-1978 vs. 1983 SEDIMENT DATA - HUDSON RIVER PCB SITE. HUDSON RIVER, NY ______ E-7 0 A Hailiburton Company ------- PCB may introduce large differences in the data sets. Without a detailed evaluation and comparison of analytical methods used in each survey, a quantification is impossible. Mechanisms including desorption and removal of PCBs from the sediments, chemical degradation of PCB compounds, and the dilution of contaminated sediments through mixing during deposition and shifting of contaminated sediments, could also account for the drop in PCB contamination. Differences of the magnitude indicated by this analysis could substantially affect the interpretation of the Hudson River PCB problem. Unfortunately, the limited amount of 1983 data prohibits a determination of whether the decrease in PCB concentration is real, as well as identification of possible physical chemical processes which could be responsible. The problem warrants further investigation. A brief discussion of results from some critical areas may give some qualitative insight into the stability and movement of PCB hot spots. Hot spot number 20 is a small marshland hot spot north of the eastern portion of Thompson Island Dam. This area has exhibited extremely high PCB values in the past. The 1983 sample from this area had a depth—weighted average of 86.6 ppm with a high value of 90 ppm occuring between 2 and 12 inches in depth. The closest NYSDEC sample point contained a depth—weighted average PCB concentration of 323 ppm. Although the later value shows much less PCB, It appears that this area is still hot. Five samples were takerf near the Thompson Island Dam to detect contaminated sediments which might have collected there. No samples were recovered from two of the stations because the bottom was either too herd or too rocky to recover sediment. The other three samples turned up no appreciable contamination. Unfortunately none of these samples fell within the boundaries at hot spot number 19. Two of the samples fell within 20 feet of previous grab samples which had indicated PCB contamination of 79.4 and 25 ppm. It may be that the drawdown behind the dam maintains a swift current which scoured the previously contaminated material and prevents further buildup of sediments. E—8 ------- Hot spot 18 is a large, highly contaminated deposit associated with a major riverbank wetland. Seven core samples were collected from this deposit in areas where PCB concentrations of between 68 and 300 ppm had been previously found. In 1983 highly contaminated sediments (170 ppm) were found near the upstream portion of the hot spot. However, six core samples collected over a small area within the lower half of the hot spot contained concentrations of less than 5 ppm. It is not known why highly contaminated sediments were not found in the downstream portion of this hot spot. Field observations indicated that the current over this deposit was rapid even though the area was surrounded by aquatic and emergent vegetation. It is possible that contaminated sediments found here in the past have moved. HighlV contaminated sediments (135 ppm) were found in a core collected near the center of the channel at the south end of Griffin Island. This area had not been sampled before, and shore line samples near this area had not indicated any appreciable contamination. Since this Is a channel location subject to high velocities, it may be that the contaminated sediments found here in 1983 have been recently deposited material from upstream hot spots. Hot spot 14 was an extensive, heavily contaminated area which contained a relatively large mass of PCB. Nearly every previous sample from this area contained PCBs in excess of 50 ppm and many contained concentrations higher than 100 ppm. Of the five samples taken from this area in 1983. only one at the extreme upstream end of the deposIt contained concentrations in excess of 50 ppm. The other samples contairTed less than 15 ppm. Members of the survey in 1983 indicated that the river bottom where they attempted to take samples was composed of hard or decomposing shale fragments. They also indicated that the current over the lower end of this area was relatively swift. The highly contaminated channel deposits reported above were found Immediately downstream of hot spot ‘14. it is suggested that the fine sediments found In hot spot 14 in 1977- 1978 have been moved downstream and that some of them have been deposited near the end of Griffin Island. E—9 ------- One core sample retrieved from hot spot twelve, less than 20 feet from a previous NYSDEC sample, contained 12.8 ppm PCBs where the previous sample contained PCBs at about 100 ppm. This may be-a reflection of the extreme variability in the distribution of contaminated sediments or it may be due to other mechanisms. Hot spot number 10 is a mid—channei deposit which was expected to show some signs of degradation or scour. However, three core samples taken within the boundaries of this hot spot, reveal that highly contaminated sediments still exist here. It is not known why this particular chanhel deposit has remained stable while others appear to have shifted. Four samples were retrieved from hot spot 8. Two samples had concentrations of more than 50 ppm and two did not. This deposit, however, is so large that a definitive statement or its status cannot be made. This is also the case with hot spot 28, which is located below Lock 6. Hot spot 6 is a large hot spot which traverses the river at Its upstream end and extends down both banks for a quarter of a mile. The 1983 survey’s most highly contaminated samples were found in the east bank areas of hot spot 6. Four sediment grabs from the upstream channel areas of this hot spot, however, did -not show the level of contamination that had been previously found. Current surface PCB concentrations In this area are only about 20 ppm. It is not known If contaminated sediments exist below the surface because the information came from grab samples. Thus it cannot be determined if the reduction in surface concentration found in the upstream portion of hot spot.6 is due to scour or the deposition of less contaminated sediment The discussions and conclusions presented above are only one interpretation of data collected from an extremely variable medium. The analysis indicates that, due to unknown mechanisms, the concentrations and distributions of PCB—contaminated sediments have undergone some degree of change since the completion of the 1977— 1978 survey. Some contaminated deposits, namely parts of hot spots 18, 14, 12 and E— 10 ------- 6, each of which contained relatively large amounts of PCBs, appear to have undergone some reduction in contamination. Other areas——particularly the hot spots 20, 17, 15, 11, 10, 5 and 4 and parts of hot spots 6, and 18——are still highly contaminated. E —1 1 ------- APPENDIX E ATTACHMENT 1 ------- / ( I . ocK ‘ FORT MILLER // ------- FORT EDWARD ------- I, / / ‘ \ / 4%.! #i / ; (I$\\ 0 \ / / N / 6 ’ 0 ‘S , / , a 0 6 I ‘I N • I 0A \ LJ 47 0 w 1 I -loT 5?oT zg’ 1’ A 4 . 4 , N 0 6 - 0 92 ------- e. 0 / / / $ 186 ‘4 ‘ 4’ I ’, 4;’ / ‘4 ‘4 I ’ 6 U / ,0 / I 5 I49 \ 9! a T I’ 0 ‘p 3 0 sa 6- I ,. / I HOT pcT / 1/ 3 0 ‘a a LKE—4T 56 CII) 93 ------- / / I.. II sPo r is 1 I / LK7 4 5PoT I 100 / I I ------- / I II / 1 / 1 LK7-40 / H 1 j 9C-4u U - : T R.7 I F’u.D. II n 0 II’ 101 ------- Is, / 6 ( ci K \ 0 0 0 :7 \ I. 7-3G , I / 0 “I I 7. .,,z I K 4 102 ------- - 2- 2 C. H .LK7-33 L$7 34A1 • : I .1 •1 / I t LK7-35 LK7- ’ 2 \ C C C C 1 ‘ ISLAND 5 6 4 S. mu 0 • ,# d / / 0 ‘1 ‘J , Li I 103 ------- ,#1 .-a.c7 \ \ \. ii. \\ / ,f . 0 0 0 0 IS? . 7-p o ‘¼ 1. H 1. poT ILt / f7 \ K7i 3 104 ------- .“lI pq / / I 1 ‘ê T c1 I / 4 •200 ‘ ‘S e 2 / F / /1 SPO T. -c4 / , —I - - -., 105 —I / 7-’ZB 0 NO T$ ------- / 4 0 - 5 SPoT / LK?-2.5.. ‘rec Ii4OT / I. / I / ‘I SPOT 11 ‘ -p 106 ------- / 1 ( j I. / / I , I! / Hor Por .1 107 7-re-Ce I I N ‘5 LK7-21 3 0 I 7 .i’Ø-CS / a C HoT S 7 / Co F ------- T5 2 ae / 0 \ t. I I OT PoT \ \ \ \ .\ 4 . 1° / 1 r 5 .9 t 3 I) Li4 0 / / / J 5 0 sa 108 ------- / / // II / ii• (I £ K7-i5 LX7- I4 J . IT ‘ *I ‘ /1 7 / I spc,T g // / rvc I i. / / / / / I 109 / ‘7- LK7-46 .. K7-I7 ------- ‘I LK7’ I2 LK7- 3 If’ •.‘V i * / \; \1 1. *4 I 4 a sr r . :. LX7u’14 LK7 - 5 I 213• •1 -i 2 o 3m’ SPoT 6 \ 110 ‘4’ “4’ SPor s, ------- I.’. / -c 0 I ;’ 3 0 $. 0 ‘ p l c 113 I 3 1 - \\ \ 2. m I \ ) I ( 2 3 4oTskor 6 S POT S a a, 4 a 3 LIc7 12 N’ * —,, , -4 L NOR r 111 ------- / I 4” ) 1• I; I / i/I / I I I I 19 ,1 0 I 1 / ‘7 J A / LK?-9 112 ------- ‘p TOwER .LK7 GA 113 ,w.D. \ 2191 \ - . . LK7-4 sq \ \ \ ‘1 HOT 1c - I / / / ------- I ‘J. 1• 1A ‘4 I ‘4 I LXI-2 O. .LD. 13 çLx 7_3 114 ------- •22 6 tE 3 \ I N \• N I N \ 12 i s or\ \ ROGERS I 115 ------- , 7 / 7 / ) SPoT j, 1/ / / I / A IS 4,vD ‘I / / 2 ‘I / / 2 . U 116 ------- ) /1 / / / ‘7 I ‘I E I. L,oc.kllCM ‘S •1 \... / / ii /. (,7 I. / / C - 117 ------- APPENDIX E ATTACHMENT 2 ------- UPPER HUDSON RIVER PCB SURVEY Procedure for Segmenting Core Samples Objective Core samplers are used to collect essentially undisturbed samples which represent the profile of strata in sediments or sludges. Core samples will be taken from Upper Hudson River sediments and analyzed for PCB contamination. Methodology Every effort will be made in the field to insure the integrity of -core samples 0 Each sample will be marked in the field ‘Top! and ‘Bottom’ and stored upright. Core samples requiring segmenting or subsampling will be frozen overnight prior to processing. Each core will be examined, measured and photographed prior to processing. The condition of the core and the color, texture and relative position of any strata will be recorded. Core liners will be cut with a pipe cutting tool. The tool should only be used to cut the liner and should not enter the core sample to any appreciable degree. A stainless steel spatula or knife will be used to subsample the sediment. Laboratory tools and work area wiLL be cleaned with distilled water, acetone and methylene chloride between each sample. Figure 1 provides a schematic of the procedure for segmenting core samples. To ensure comparability of data collected with the existing data base, cores will be segmented in the following manner. • Uniform Core - one sample taken from the top 3”; one sample from the remainder of the core. • Uniform Core top- 12” with strata below - one sample taken from the top 3”; one sample taken from the remainder of the strata and one each from each remaining strata 0 • Stratified Core - one sample from each strata. Stratification within the core shall be defined by significant changes in texture, color or grain size of sediments. Strata will be recognized through gross examination of cores and sampled when sufficient volumn is present for laboratory analysis. Samples taken from the various cores will be placed into 8 oz. glass jars and shipped using normal chain of custody procedures ------- TOP _T SAMPLE ) i 3’• SAMPLE —p SAMPLE—42” SAMPLE >12” SAMPLE > SAMPI..E—.—4’ SAMPLE —+ Indivi i1 san 1e f iu tcp 3” and san 1e f iu rEnainder of the re. Indivjr mil s 1e fran each strata. PROCEDURE FOR SEGMENTING CORE SAMPLES FiGURE 1 NUB - ORPC A11 N SAMPLE SAMPLE ------- UPPER HUDSON RIVER PCB SURVEY Procedure for Segmenting Core Samples Objective Core samplers are used to collect essentially undisturbed samples which represent the profile of strata in sediments or sludges. Core samples wilt be taken from Upper Hudson River sediments and analyzed for PCB contamination. Methodology Every effort wilt be made in the field to insure the integrity of core samples. Each sample will be marked in the field ‘Top’ and ‘Bottom’ arid stored upright. Core samples requiring segmenting or subsampling will be frozen overnight prior to processing. Each core will be examined 9 measured and photographed prior to prDcessing. The condition of the core and the color, texture and relative position of any strata will be recorded. Core liners will be cut with a pipe cutting tool. The tool should only be used to cut the liner and should not enter the core sample to any appreciable degree. A stainless steel spatula or knife will be used to subsample the sediment. Laboratory tools and work area will be cleaned with distilled water, acetone and methylene chloride between each sample. Figure 1 provides a schematic of the procedure for segmenting core samples. To ensure comparability of data collected with the existing data base, cores will be segmented in the following manner, • Uniform Core one sample taken from the top 3”; one sample from the remainder of the core. • Uniform Core top 12” with strata below - one sample taken from the top 3”; one sample taken from the remainder of the strata and one each from each remaining strata. • Stratified Core - one sample from each strata. Stratification within the core shall be defined by significant changes in texture, color or grain size of sediments. Strata will be recognized through gross examination of cores and sampled when sufficient volumn is present for laboratory analysis. Samples taken from the various cores will be placed into 8 oz. glass jars and shipped using normal chain of custody procedures. ------- Ir dividua 1 sa le fran top 3” ax s t 1e £ R rEna.thder of the re. TOP SAMPLE— 3” SAMPLE >12” I SAMPt.E— Individual sample fran each strata. PROCEDURE FOR FiGURE 1 SEGMENTING CORE NUB - CPPCRATCN SAMPLE — 3” k - SAMPLE SAMPLE—.-.- SAMPLE 4 . ; SAMPLES ------- ANALYSIS OF PCBs IN HUDSON RIVER SEDLMENTS SAMPLE PREPARATION AND EXTRACTION I. Thoroughly mix the sample. 2. Ac urataly weigh and record the desired quantity of prepared sample, commonly 50 gm. 3. In a 250 ml Erfenmeyer flask, mix the sample and a sufficient quantity of 1:1 (v/v) acetone-hexane to produce a slurry. 4. Place on a mechanical shaker for thirty minutes. 5. Decant the solvent to a separatory funnel containing 500 ml disthled water. 6. Add 25 ml of 1:1 (v/v) acetone-hexane to the flask and shake for an additional 30 minutes. 7. Repeat Steps 5 and 6 and combine all extracts. 8. DIscard the aqueous layer, wash with two 500 ml portion of distilled water and discard the washings. 9. A : sufficient quantity of anhydrous sodium su1fat to ‘1ve crystals that aro free flowi i unon wirli1’!. 10. Concentrate volume to 10 ml in a Kuderna—Danish evaporator, 11. Proceed with steplO.3 of the attached”Me hod for Polychiorinated Biphenyls (PC3s) In Water and Wastewater published in EPA 600/4— 81 ..054, Methods for Benzidine, Chlorinated Organic Comoounds, Pentachloropherrol and Pesticides in Water and Wastewater , Seot. 1978. NOTE: Report results In terms of ug g dry weight based upon weight loss obtained by dryi 1 ig at 60 C. Report the individual PCBs and total PC3s. ------- M TH0D FOR POL?CHLORINATED BIPHENYLS (PCBs) IN WATER AND WASTEIJIATER 1. Scooe and ADplicatlon 1.1 This method covers the determination of various polychlorlnatad biphenyl (PC3) mixtures In water and wastewater. 1.2 The fo11 1ng mixtures of chlorinated biphenyls (Aroclors) may be determined by this method: Parameter Storet No . PC3- 1015 34671 PCB—1221 39488 PC3— 1232 39492 PCS—1242 39496 PCB—1248 39500 PCS .- 1254 39504 PCB- 1 260 39508 1.3 The method Is an extension of the Method for C i1or1nated Hydrocarbons in Water and Wastewater (1). It is designed so that determination of both the PC3s and the organochlorlne pesticides may be made on the same sample. 2. Sunvnary 2.1 The PCSs and the organochioririe pesticides are co—extracted by liquid—liquid extraction and, insofar as possible, the two classes of compounds separated from one another prior to gas chromatographic. determination. A contination of the standard Florisil column cleanup procedure and a silica gel microcolumn separation procedure (2)(3) are employed. Identification is 43 ------- made from gas chromatographic patterns obtained through the use of two or more unlike columns. Detection and measurement is accon llshed using an electron capture, rnicrocoulcmetric, or electrolytic conductivity detector. Techniques for confirming qualitative identification are suggested. 3. Interferences 3. 1 Solvents, reagents, glassware, and other san le processing hardware may yield discrete artifacts and/or elevated baselines cau si ng nrf Si nterpretat ion of gas chromatograms. Al 1. of these materials mist be. demonstrated to be free from interferences under the conditions 0 f the analysis. Specific selection of reagents and the purification of solvents by distillation in all-glass systen may be required. Refer to Appendix I. 3.2 The interferences In Industrial effluents are high and varied and pose great difficulty In obtaining accurate and precise measurement of PCBs and organochioririe pesticides. Separation and clean—up procedures are generally required and may result in the loss ol certain organochiorine c rr ounds. Therefore, great care should be exeroised in the selection and use of methods fo eliminating or minimizing Interferences. It Is not possible to describe procedures for overcoming all of the interferences that may be encountered in industrial effluents. 3.3 Phttialate esters, certain orgartophosphorus pesticides, and elemental sulfur wifl interfere when using electron capture for detection. These materials do not interfere when the 44 ------- rnicrocoulornetric or electrolytic conductivity detectors are used in the halogen mode. 3.4 Organochlorlne pesticides and other halogenated compounds constitute interferences in the determination of PC8s. Most of these are separated by •the method described below. However, certain compounds, if present.in the sample, will occur with the PCBs. Included are: Sulfur,. Heptachior, aldrin, DDE, technical chlordane, nirex, and to some extent, o,p’-DDT and p,p’-CDT. 4. ADparatus and Materials 4. 1 Gas Chromatograph - Equipped with glass lined injection port. 4.2 Detector Options: 4.2.1 Electron Capture - Radioactive (tritium or nlckeT-63) 4.2.2 Mlcrocoulometric Titration 4.2.3 Electrolytic Conductivity 4.3 Recorder - Potentlometric strip chart (10 in.) compatible with the detector. 4.4 Gas Chromatograph I c Column Materials: 4.4.1 Tubing Pyrex (180 cn long X 4 im ID) 4.4.2 Glass Wool - Sllanized 4.4.3 Solid Support — Gas—Chrom Q (100—120 mesh) 4.4.4 Liquid Phases - Expressed as weight percent coated on solid support. 4.4.4.1 SE-30 or OV—1, 3% 4.4.4.2 - OV—17, 1.5% + QF-l or OV—210, 1.95% 45 ------- 4.5 Kuderna—Oartish-(K—C) Glassware 4.5.1 Snyder Column - three—ball (macro) and two—ball (micro) 4.5.2 Evaporative flasks - 500 ml 4.5.3 Receiver Ampuls - 10 ml, graduated 4.5.4 Ampul Stoppers 4.6 C iromatographlc Column Chromaflex (400 rrri long x 19 rim ID) with coarse fritted plate on bottom and Teflon stopcock; 250-mi reservoir bulb at top of column with flared out funnel shape at top of bulb - a special order (Kontes K.-420540—9011). 4.7 Chromatographic Column - pyrex (approximately 400 nm long x 20 nm ED) with coarse fritted plate on bottom. 4.8 Micro Column Pyrex - constructed according to Figure 1. 4.9 CapIllary pipets disposable (5—3/4 In.) with rubber bulb (Scientific Products P5205—I). 4.10 Low pressure regulator - 0 to 5 PSIG - with low—flow needle valve (see FIgure 1, Matheson Model 70). 4.11 Beaker - 100 nil 4.12 MIcro Syringes - 10, 25, 50 and 100 ul. 4.13 . Separatory funnels — 125 ml, 1000 ml and 2000 ml with Teflon stopcock, 4.14 Blender High speed, glass or stainless steel cup. 4.15 Graduated cylinders 100 and 250 ml. 4.16 Florisil - PR Grade (60—100 mesh); purchase activated at 1250 0 F and store in the dark in glass containers with glass stoppers or foil-lined screw caps. Before use, activate each 46 ------- AIR SUPPLY SHUT-OFF VAt_yE REGULATOR PRESSURE 0 • 5 GAUGE VALVE SILICA GEL 5cm Icm{ I cm FLEXIBLE TUBING 10/30 15m 1 10/30 23cm x 4.2mm 1.0. 2cm x 2 mm 1.0. FIGURE I. SYSTEM 3 , M l CROCOLUMN 47 ------- batch overnight at 130°C in fofi-covered glass container. Detertnirte lauric-acid value (See Appendix U). 4.17 Silica gel - Davison code 950—08008—226 (60/200 mesh). 4.18 Glass Wool - Hexane extracted. 4.19 Centrifuge Tubes Pyrex calibrated (15 ml). 5. Reagents, !olvents, and Standards 5.1 SodIum Chloride - (ACS) Saturated solution In distilled water (pre-rinse MaCi with hexarie). 5.2 Sodium Hydroxide - (ACS) 10 N In distilled water. 5.3 Sodium Sulfate (ACZ) Granular, anhydrous (c nd1tioned at 400° C for 4 hrs.). 5.4 SulfurIc Acid (ACZ) Mix equal volumes of conc. H SO 4 with distilled water. 5.5 Diethyl Ether - Nanograde, redlstflled in glass, if necessary. 5.5.1 bst be free of peroxides as indicated by EM Quart test strips. (Test strips are ava l1aD1e front EM Labora- tories, Inc., 500 Executive Blvd., Elmsford, N.Y. 10523). 5.5.2 Procedures recotmnended for removal of peroxides are provided with the test strips. 5.6 n —Hexane Pesticide quality (NOT MIXW KEXANES). 5.7 Acetonitrile, Hexane, Methanol, Methylene Chloride, Petroleum Ether (boiling range 30—60°C) - pesticide quality, redistill in glass if necessary. 503 Standards Aroclors 1221, 1232, 1242, 1243, 1254, 1260, and 1016. 43 ------- 5.9 Anti-static Solution - STATNUL, Daystrom, Inc., Weston Instru- ment Division, Newark, N.J., 95212. 6. CalibratIon 6.1 Gas chromatographic operating conditions are considered accept- able if the response to dicapthon Is at least 50% of full scale when 0.06 ng is injected for electron capture detection and 100 ng is injected for rnicrocoulometric or electrolytic con- ductivity detection. For all quantitative measurements, the detector must be operated within its linear response range and the detector noise level should be less than 2% of full scale. 6.2 Standards are injected frequently as a check on the stability of operating conditions, detector and column. Example chro- matograms are shown in Figures 3 through 8 and provide reference operating conditions. 7. QualIty Control 7.1 Duplicate and spiked sample analyses are recomended as quality control checks. Quality control charts (4) should be developed and used as a check on the analytical system. Quality control check samples and performance evaluation samples should be analyzed on a regular basis. 7.2 Each time a set of samples is extracted, a method blank is determined on a volume of distilled water equivalent to that used to dilute the sample. 8. Samole Preparation 8.1 Blend the sample if suspended matter is present and adjust pH 49 ------- to near neutral (pH 6.5-7.5) with 50% sulfuric acid or 10 N sodium hydroxide. 8.2 For sensitivity requirement of 1 g/1, when using micro— coulometric or electrolytic conductivity methods for detection take 1000 ml of sai 1e for analysis. If interferences pose no problem, the sensitivity of the electron capture detector should p -in1t as little as 100 nil of san le to be used. Back- ground information on the extent and nature of interferences will assist the analyst in choosing the required san 1e size and preferred detector. 8.3 QuantitatIvely transfer the proper aliquot Into a two—liter separatory funnel and dilute to one liter. 9. ExtractIon 9.1 Add 60 ml of 15% methylene chloride In hexane (v:v) to the san 1e in the separatory funnel and shake vigorously for two minutes. 9.2 Allow the mixed solvent to separate from the san 1e, then draw the water into a one—liter Erlermieyer flask. Pour the organic layer into a 100—mi beaker and then pass it through a column containing 3-4 inches of anhydrous sodium sulfate, and collect it in a 500-mi K-O flask equipped with a 10 ml—an u1. Return the water phase to the separatory funnel. Rinse the Erlenmeyer flask with a second 60—mi volume of solvent; add the solvent to the separatory funnel and complete the extraction procedure a second time. Perform a third extraction in the same manner. 50 ------- 9.3 Concentrate the extract in the K—O evaporator on a hot water bath. 9.4 Qualitatively analyze the sample by gas chromatography with an electron capture detector. From the response obtained decide: a. If there are any organochlorfne pesticides present. b. If there are any PCBs present. c. If there Is a contination of a and b. d. If ele ienta1 sulfur is present. e. If the response is too con lex to determine a, b or C. f. If no response, concentrate to 1.0 ml or less, as. required, and repeat the analysis looking for a, b, c, d, and e. Samples containing Aroclors with a low percentage of chlorine, e.g., 1221 and 1232, may require this concentra- tion In order to achieve the detection limit of 1 ugh. Trace quantities of PCSs are often masked by background which usually oc ir In samples. 9.5 If condition a exists, quantitatively determine the organo- chlorine pesticides according to (1). 9.6 If condition b exists, PC3s only are present; no further separation or cleanup is necessary. Quantitatively determine the PCBs according to step ‘11. 9.7 If condition e exists, coir are peaks obtained from the sample to those of standard Aroclors and make a judgment as to wbich Aroclors may be present. 1o separate the PC3s from the organo— chlorine pesticides, continue as outlined in 10.4. 51 ------- g . If condition d exists, separate the sulfur from the sample using the method outlined in 10.3 followed by the method in 10.5. g,g If condition e exists, the following macro cleanup arid separa— tiort procedures (10.2 and 10.3) should be employed and, if necessary, followed by the micro separation procedures (10.4 and 10.5). 10. Cleanuo and Seoaratlon Procedures 10.1 Interferences in the form of distinct peaks and/or high back- ground th the initial gas chromatographic analysis, as well as the physical characteristics of the extract (color, cloudiness, viscosity) and background knowledge of the sample will indicate whether clean-up is required. When these Interfere with measurement of the PC3s, or affect column life or detector sensitivity, proceed as directed below. 10.2 Acetonitrile Partition - This procedure is used to remove fats and oils from the sample extracts. It should be noted that not all pesticides are quantitatively recovered by this procedure. The analyst mist be aware of this and demonstrate the effi ciency of the partitioning for the compounds interest. 10.2.1 Quantitatively transfer the previously concentrated extract to a 125—mi separatory funnel with enough hexane to bring the final volume to 15 m i, Extract the sample four times by shaking vigorously for one minute with 30-mi portions of hexane—saturated acetonitrile. 52 ------- 10.2.2 Combine and transfer the acetonitrfle phases to a one—liter separatory funnel and add 650 ml of distilled water and 4.0 rn.l of saturated sodium chloride solution. Mix thoroughly for 30-45 seconds. Extract with two 100-mi portions of hexane by vigorously shaking about 15 seconds. 10.2.3 Contlne the hexane extracts In a one—liter separatory funnel and wash with two 100—mi portions of distilled water. Discard the water layer and pour the hexane layer through a 3-4 Inch anhydrous sodium sulfate column into a 500—mi K-0 flask equipped with a 10—mi a,i u1. Rinse the separatory funnel and column with three 10—mi portions of hexane. 10.2.4 Concentrate the extracts to 6—10 ml in the K—0 eva- porator in a hot water bath. 10.2.5 Analyze by gas chromatography unless a need f or further cleanup Is indicated. 10.3 Florlsll Column Adsorption Chromatography 10.3.1 Adjust the san le extract volume to 10 ml. 10.3.2 Place a charge of activated Florisil (weight determined by lauric-acid value, see Appendix II) in a Chromaflex column. After settling the Florisil by tapping the column, add about one-l a1f inch layer of anhydrous granular sodium sulfate to the too. 53 ------- 10.3.3 Pre—elute the column, after cooling, with 50—60 ml of petroleum ether. Discard the eluate arid just prior to exposure of the sulfate layer to air, quantitatively transfer the sample extract into the column by decaritaticn and subsequent petroleum ether washings. Adjust the elution rate to about 5 ml per minute and, separately, collect up to three eluates In 500-m I K-O flasks equipped with 10-mi ampuls (see Eluate Composi- tion 10.4.). Perform the first elution with 200 ml of 6% ethyl ether in petroleum ether, and the second elution with 200 ml of 15% ethyl ether in petroleum ether. Perform the third elutlon with 200 ml of 50% ethyl ether - petroleum ether and the fourth elution with 200 ni of 100% ethyl ether. 10.3.3.1 Eluate Composition — By usi rig an equivalent quantity of any batch of Florisli as deter- mined by its lauric acid value, the pesti- cides will be separated into the eluates Indicated as follows. 6% Eluate Aidrin DOT Peritach1cro BHC Heptach lor riitrobenzene ailordane Heptachior Epoxide Strobane DOD Lindane Toxaphene ODE Methoxychior Trifluralin Mlrex PCSs 15% Eluate 50% Eluate Endasulfan I èsulfan El Endrin Captan Dieldrirt Dich loran Phthalate esters 54 ------- Certain thiophosphate pesticides will occur in each of the above fractions as well as the 100% fraction. For additional information regarding eluate composition, refer to the FDA Pesticide Analytical Manual (5). 10.3.4 Concentrate the eluates to 6—10 ml in the K-0 evaporator In a hot water bath. 10.3.5 Analyze by gas chromatography. 10.4 SIlica Gel Micro-Column Separation Procedure (6) 10.4.1 Actlvaticn for Silica Gel 10.4.1.1 Place about 20 of silica gel in a 700—mi beaker. Activate at 180°C for approximately 16 hours. Transfer the silica gel to a 100—mi glass—stoppered bottle. When cool, cover with about 35 ml of 0.50% diethyl ether in benzene (volume:volume). Keep bottle 11 sealed. f silica gel collects on the ground glass surfaces, wash off with the above solvent before resealing. Always maintain an excess of the mixed solvent in bottle (aproxTmately 1/2 in. above silica gel). Silica gel can be effectively stored in this manner for several days. 10.4.2 Preparation of the C tromatographic Column 10.4.2.1 Pack the lower 2 rmT ZD s ection of the micro— column with glass wool. Permanently mark 55 ------- the column 120 m it above the glass wool. Using a clean rubber bulb from a disposable pipet seal the lower end of the microcolumn. Fill the mlcrocolumn with 0.50% ether in benzene (v:v) to the bottom of the 10/30 joint (Figure 1). Using a disposable capillary pipet, transfer several aliquots of the silica gel slurry into the microcolumn. After approxi— rnately 1 an of silica gel collects in the bottom of the inicroco lunm, remove the rubber bulb seal, tap the column to insure that the silica gel reaches the 120 2 nm mark. Be sure that there are no air bubbles in the column. Add about 10 nmn of sodium sulfate to the top of the silica gel. Under low humidity conditions, the silica gel may coat the sides of the column and not settle properly. This can be minimized by wiping the outside of the column with an anti-static solution. 10.4.2.2 Deactivation of the Sflica Gel a. Fill the mcrocolumn to the base of the 10/30 joInt with the 0.50% ether. .benzene mixture, assen le reservoir (using. spring clamps) and fill with approximately 15 ml of the 0.50% ether-benzene mixture. Attach the air pressure device (using spring 56 ------- clamps) and adjust the elution rate to approximately 1 mi/mm. with the air pressure control. Release the air pressure and detach reservoir just as the last of the solvent enters the sodium sulfate. Fill the column with n—hexane (not mixed hexanes) to the base of the 10/30 fItting. Evaporate all residual benzene from the reservoir, assemble the reservoir section and fill with 5 ml of n-.hexane. Apply air pressure and remove the reservoir just as the n-hexane enters the sodium sulfate. The column, is oow ready for’ use. b. Pipet a 1.0 ml aliquot of the concentrated sample extract (previously reduced to a total volume of 2.0 ml) on to the column. As the last of the sample passes into the sodium sulfate layer, rinse down the internal wall of the column twice with 0.25 ml of n—hexane. Then assemble the upper section of the column. As the last of the n—hexane rinse reaches the surface of the sodium sulfate, add enough n—hexane (volume predetermined, see 10.4.3) to just eTute all of the PCSs present In the sample. Apply air pressure and adjust until the 57 ------- flow is 1 mi/mm. Collect the desired volume of eluate (predetermined, see 10.4.3) In an accurately calibrated an u1. As the last of the n—hexane reaches the surface of the sodium sulfate, release the air pressure and change the collection asnpu 1. c. Ff11 the column with 0.50% diethyl ether In benzene, again apply air pressure and adjust flow to 1 ml/mnin. Collect the eluate until all of the orgariochiorine pesticides of interest have been eluted (volume prdetermined, see 10.4.3). d. Analyze the eluates by gas chromatography. 10 .4.3 Determination of 1ution Volumes 10.4.3.1 The elution volumes for the PCBs and the pesticides depend upon a nunter of factors hith are difficult to control. These include variation in: a. Mesh size of the silica gel b Adsorption properties of the silica gel c. Polar contaminants present in the eluting solvent d. Polar materials present in the sar, le..and sample solvent 58 ------- e. The dimensions of the microcolumns Therefore, the optimum elution volume must be experimentally determined each time a factor is changed. To determine the elution volumes, add standard mixtures of Aroc1or and pesticides to the column and serially collect 1-nil elution volumes. Analyze the individual eluates by gas chromatography and determine the cut-off volume for n—hexane and for ether-benzene. FIgure 2 shows the retention order of the various PC! con onents and of the pesti- cides. Using this Information, prepare the mixtures required for calibraton of the inicroco lumn. 10.4.3.2 In determining the volume of hexane required to elute the PC3s the sample volume (1 ml) and the volume of n—hexane used to rinse the colunwi wall rmjst be considered. Thus, If It Is determined that a 10.0—mi elution volume is required to elute the PC3s, the volume of hexane to be added in addition to the sample volume but including the rinse volume should be 9.5 ml. 59 ------- E TACIILOR DE AL IN DAIIE ECHNflCAL CHIORO 50 260 40 -J 4 1- 4 0 a) a 30 1 ’ 0 I I I—. 2 2fl I ft I d a- I0 u 2 4 6 8 J I ------- 10.4.3.3 Figure 2 shows that as the average chlorine content of a PCB mixture decreases the solvent volume f r o lete elution increa.ses. Quali- tative determination (9 ,4) Indicates which Aroclors are present and. provides the basis for selection of the Ideal elution volume. This helps to minimize the quantity of organo chlorine pesticides which will elute along with the low percent chlorine PC3s and insures the most efficient separations possible for accurate analysis. 10.4.3.4 For critical analysis where the PC3s and pesti— cides are not separated con 1ete1y, the coli.mui should be accurately calibrated according to (10.4.3.1) to determine the peroent of material of interest that elutes in each fraction. Then flush the column with an additIonal 15 ml of 0.50% ether in b izene followed by 5 ml of n-hexane and use this reconditioned column for the san 1e separation. Using this technique one car accurately predict the amount (%) of materials in each micro column fraction. 10.5 Micro Column Separation of Sulfur, PCBs, and Pesticides 10.5. 1 See procedure for preparation and packing micro column in PCB analysis section (10.4.1 and 10.4.2). 61 ------- 10.5.2 Microcolumn Calibration 10.5.2.1 Calibrate the microcclumn for sulfur and PCB separation by collecting l.0—ITI1 fractions and analyzing. them by gas chromatography to determine the following: 1) The fraction with the first eluting PCSs (those present in 1260), 2) The fraction with the last.eluting PCSs (those present in 1221), 3) The elution volume for sulfur,. 4) The elution volume for the pesticides of interest in the 0.50% ether-benzene fraction. From these data determine the following: 1) The eluting volume containing only sulfur (Fraction I), 2) The eluting volume containing the last of the sulfur and the early eluting PC8s (Fraction II) , 3) The eluting volume containing the remaining PC3s (Fraction III), 4) The ether-benzene e1utir g volume containing the pesticides of thterest (Fraction I V). 10.5.3 separation Procedure 10.5.3.1 Carefully concentrate the 6 eluate from the 62 ------- florisil column to 2.0 ml in the graduated arnpul on a warm water bath. 10.5.3.2 Place 1.0 ml (50%) of the concentrate into the microcolwnn with a 1-mi pipet. Be careful not to get any sulfur crystals into the pipet. 10.5.3e3 Collect Fractions I and II in calibrated centrifuge tubes. Collect Fractions III and IV in calibrated ground g1a s stoppered ampuls. 10.5.3.4 Sulfur Rei oval (7) - Add 1 to 2 drops of mercury to Fraction II stopper and place on a wrist-action shaker. A black precipitate indicates the presence of sulfur. After approximately 20 minutes the mercury may become entirely reacted or deactivated by the precipitate. The sa 1e should be quariti- tatively transferred to a clean centrifuge tube and additional mercury added. When crystals ai-e present in the san le, three treateents may be necessary to remove all the. sulfur. After all the sulfur has been removedfrom Fraction II (check using gas chromatography) combine Fractions II and III. Adjust the volume to 10 ml and analyze by gas chromatography. Be sure no mercury is transferred to the combined Fractions H and III, since it can react with certain pesticides. 63 ------- By combining Fractions I I and H , if PC8s are present, it is possible to identify the Aroclor(s) present and a quantitative analysis can be performed accordingly. Fraction r can be discarded since it oniy contains the bulk of the sulfur. Analyze Fractions I II and IV for the PCSs and pesticides. If CDT and its hontlegs,. a ldrin, heptachlor, or technical chlordane are present along with the PCSs, an additional raicrocolunin separation can be performS which may help to further separate the PC3s from the pesticides (See 10.4). 11. Quantitative Determination 11.1 Measure the volume of rt—hexane eluate containing the PCZs and inJect 1 to 5 , l into the gas chromatograpri. If necessary, adjust the volume of the eluate to give linear response to the electron capture detector. The ml crocou I ometri c or the electrolytic detector may be ei loyed to improve specificity for samples having higher concentrations of PCBs. 11.2 CalculatIons 11.2.1 When a single Aroclor is present, compare quantitative Aroclor reference standards (e.g., 1242, 1250) to the unknown. Measure and sum the areas of the unknown and the reference Aroclor and calculate the result as fo I lows: 64 ------- Microgram/Uter X [ N ] A na of Standard rniected B of Sample Peak Areas - ( 2) = Volume of saii le injected (ul) Volume of Extract (U!) from which sample is injected into gas chromatograph V 5 Volume of water sample extracted (ml) N 2 when micro column used 1 when nrtcro column not used Peak Area Peak height (im x Peak Width at 1/2 height 11.2.2 For complex situatons, use the calibration method described below (3). Small variations In co onents between different Aroclor batches make ft necessary to obtain samples of several specific Proc lors. These reference Aroclors can be obtained from the Southeast Environmental Research Laboratory, EPA, Athens, Georgia, 30601. The procedure is as follows: ll.2.2.1’Using the OV-l column, chromatograph a known quantity of each Araclor reference standard. Also chromatograph a sample of p,p’-ODE. Suggested concentration of each standard is 0.1 ng/ul for the Aroclors and 0.02 ng/Ul for the p,p ‘—ODE. 65 ------- 11.2.2.2 Determine the relative retention time (RST) of each PC3 peak in the resulting chrcmatograms using p,p’-ODE as 10 0. RTx 100 RR RRT Relative Retention lime RI Retention time of peak of interest s Retention time of p,p’-ODE Retention time is measured as that distance in rim between the first appearance of the solvent peak and the maximum for the convoiznd. 11.2.2.3 To calibrate the instrument for each PCB measure the area of each peak. Area • Peak height (an) x Peak width at 1 12 height. Using Tables 1 through S obtain the proper mean weight factor, then determine the response factor ng/rvn 2 . (ng 1 ) ( mean wei qt’t percent ) , . 2 100 ng/rIn — (Area) ng 4 • ng of Aroclor Standard Injected Mean weight percent - obtained from Tables I through 6. 11.2.2.4 Calculate the RRT value and the area for each PCE peak in the sample chromatogram. Compare the sample chromatogram to those obtained for each reference Aroclor standard. tf it is 66 ------- Table Con os1tion of Aroclor .1221 (8) Mean . RRTa Weight Percent Rel Std. ative Dev.b Number of Ch lorinesC 11 31.8 15.8 1 14 19.3 9.1 1 16 10.1 9.7 2 19 2.8 9.7 2 21 20.8 9.3 2 28 5.4 13.9 2 ., 85% 1 w 32 1.4 30.1 2 3 10% 90% 37 1.7 48.8 3 40 aRetention time relative to p,p’—DDE 10O. Measured from first appearance of solvent. Overlapptng peaks that are quantitated as one peak are bracketed. b5tandard devi ation of seventeen results as a percentage of the mean of the results. cFrom GC-MS data. Peaks containing mixtures of Isomers 0 f different cfllorine nurthers are bracketed. 67 ------- Table 2 ConVosltlon of Ar c1or 1232 (8) Rwra Mean Weight Percent Relative Std. Dev.b Number-of ChlortnesC 11_ 16.2 3.4 1 14 9.9 2.5 1 16 7.1 6.8 2 20 17.8 2.4 2 21 28 9.6 3.4 2 40% 3 50% • 32 3 .9 4.7 3 37 6.8 2.5 3 40 6.4 2.7 3 47 4.2 4.1 4 54 3.4 3.4 3 33% 4 67% 58 2.5 3.7 4 70 4.6 3.1 4 90% 5 10% 78 1.7 7.5 4 Total 94.2 aR nti time relative to p,p 1 -OOE lC0. Measured from first appearance of solvent. Overlapping peaks that are quantltated as one peak are bracketed. b5t dard deviation of four results as a mean of the results. Cffrom GC MS data. Peaks containing mixtures of isomers of-different chlorine riunters are bracketed. 68 ------- Table 3 Ccnposition of Aroclor 1242 (8) Mean Weight Relative b Nrber of RRTa Percent Std. 0ev. C),lorinesC 11 1.1 35.7 1 16 2.9 492 2 21 11.3 3.0 2 28 11.0 5.0 2 25% ., r w 32 6.1 4.7 3 37 11.5 5.7 3 40 11.1 6.2 3 47 8.8 4.3 4 54 6.8 2.9 3 33% 4 67% 58 5.6 -3.3 4 70 10.3 2.8 4 90% 5 10% 78 3.6 4.2 4 84 2.7 9.7 5 98 1.5 94 5 104 2.3 16,4 5 125 1.6 20.4 5 85% 6 15% 146 l.0 19.9 5 75% 6 25% aRetention time relative to p,p’—0DE 100. Measured from first appearance of solvent. b5t dard deviation of six results as a percentage of the mean of the results. CFrom GC—MZ data. Peaks containing mixtures of isomers of different chlorine nurtters are bracketed. 69 ------- Table 4 Con osition of Aroclor 1248 (8) Mean Weight Relative Number of RRTa Percent Std. Dev.b . ChlorinesC 21 1.2 23.9 2 28 5.2 3.3 3 32 3.2 3.8 3 47 8.3 3.6 3 40 8.3 3.9 3 85% 4 15% 47 15.5 1.1 4 54 9.7 6.0 3 10% 4 90% 58 9.3 5.8 4 70 19.0 1.4 4 80% 520% 78 6.5 2.7 4 84 4.9 2.6 5 98 3.2 3.2 5 104 3.3 3.6 4 10% 5 90% 112 1.2 6.6 5 125 2.6 5.9 5 .90% 6 10% 146 1.5 10.0 5 85% U Total 103.1 aRetention time relative to p,p -0DEl00. Measured from first appearance of solvent. deviation of six results as a percentage of the mean of the, results. CFrom GC . MS data. Peaks containing mixtures of Isomers of different chlorine nuriters are bracketed. 70 ------- Table 5 Ca tpositiori of Aroclor 1254 (8) Mean Weight Relative b Number of RRTa Percent Std. 0ev. ChlorInesC 47 6.2 3.7 4 54 2.9 2.6 4 58 1.4 2.8 4 70 13.2 2.7 4 25% 5 75% 84 17.3 1.9 5 98 7.5 5.3 5 104 13.6 3.8 5 125 15.0 2.4 5 70% 6 80% 146 10.4 2.7 5 30% 5 70% 160 1.3 8.4 6 174 8.4 5.5 6 203 1.8 18.5 6 232 1.0 26.1 7 Total 100.0 aRetention time relative to p,p -ODE=l00. Measured from first appearance of solvent. b ndard deviation 0 f six results as a percentage of the mean of the results. Cffr GC-MS c ata. Peaks containing mixtures of isomers are bracketed. 71 ------- Table 6 Con osition of Aroclor 1260 (8) Mean Weight Relative b Nimter of RRT 4 Percent Std. 0ev. Chiorlnes 70 2.7 5.3 5 84 47 1.5 5 98 3.8 3.5 d 104 5 60% 6 40% 117 3.3 6.7 6 125 12.3 3.3 5 15% J . 146 14.1 3.6 6 160 4.9 2.2 6 50% 7 50% 174 12.4 2 .7 6 203 9.3 4.0 6 10% 7 90% 232 e 244 9.8 3.4 6 10% 7 90% 280 11.0 2.4 7 332 4.2 5.0. 7 372 4.0 8.6 8 448 .6 25.3 8 528 1.5 10.2 8 Total 98.6 aRetention time relative to p,p ODE 100. Measured from first appearance of solvent. Overlapping peaks that are quantitated as one peak are bracketed. bStandard deviation of six results as a mean of the results. CFram GC MS data. Peaks containing mixtures of isomers of different chlorine nurters are bracketed. dCcmposltlon determined at the center of peak 104. eCompositian determined at the center of peak 232. 72 ------- apparent that the PCB peaks present are due to only one Aroclor, then calculate the concen- tration of each PCB using the following formula: ng PCB ng/m 2 x Area Where Area Area (m 2 ) of sample peak ng/m 2 Response factor for that peak measured. Then add the nanogran of PCBs present In the Injection to get the total nur ber of nanograms of PCBs present. Use the following formula to calculate the concentration of PCBs in the sanv 1 e: Micrograms/Liter a volume of water extracte (ml) Vt volume of extract ( al) V 1 volume of sample injected ( l) ng • sum of all the PCBs in nanograms for that Aroclor identified N 2 when microcolumn used N a when microcolumn not used The value can then be reported as micro— gran5/liter PCSs or as the Aroclor. For samples containing more than one Aroclor, use Figure 9 chromatogram divisional flow chart to assign a proper response factor to each peak and also identify the t ’most llkelyu Aroclors 73 ------- present. Calculate the ng of each PCB isomer present and sum them accOrding to the divisional flow chart. Using the formula above, calculate the concentration of the various Aroclors present In the saIT le. 12. Reoort1n Results 12.1 Report results in microgran per liter without correction for recovery data. When duplicate and spiked samples are analyzed,- all data obtained should be reported. 74 ------- 37 AROCLOR 1242 70 78 Figure 3. Column: 3% OV-1, Carrier Gas: Nitrogen at 60 mI/mm, Column Temperature: 170 C, Detector: Electron Capture 125 146 75 ------- Figure 4. Ca umn: 3% OY•1, Carrier Gas: Nitrogen at 60 mI/mm, Column Temperature: 170 C, Detector: Electron Capture. 76 70 AROCLOR 1254 125 174 ------- ii Figure 5. Column: 3% OY•1, Carrier Gas: Nitrogen at GO mi/mm, Column Temperature: 170 C, Detector: Electron Capture. AROCLOR 1260 280 372 521 77 ------- 3 S 9 12 15 RETENTION TIME IN 6. Colunrn: 1.5% OY17 + 1.35% nil/mm, Ca uinn Temperature: 200 18 21 24 MINUTES ÜF•1, Carrier gas: Nitrogen C, Oetectnr: Electran Capture. AROCLOR 1242 I I I a Figure at 60 I I 78 ------- HIINIIOI IIMI IN MINUJU Figuie 7. Columi: 1.5% OV•l7 1 1.95% O1•l, CauI.r Gas: NIti.is. at Detect.,: Ilseti.. Capluis. SO mi/mi., C.Ivm . Temperatute: 200 C, -.1 lb 1 1OCt01 1254 IaJ -. 0 3 9 S 12 IS IS 21 21 27 39 33 31 39 42 45 ------- I- I . 0 3 $ S 1? IS i i 21 21 U IIUNT ION TIMI Ilguts S. CsIwng: 1 .5% OV•U I 1.55% 01.1. Csulsr Gu: Niliogs. at IN NINUU S 10 mI/mis, Celumu 1smps, Iurs: 200C. Ostscto.: (Isction Capluis. Q Aloctol 1250 I I I I I I I I I I II 33 35 3$ 42 45 4$ SI SI ------- L RRT of first peak 47? Is there a distinct peak w ith RRT 78? YES / \\No I Use 1242 for Use 1242 for 1peaks . UT 84 peaks . Ui 701 /r [ Is there a d stioct peak with RRT 117? YES NO Use 1254 for, all psaks . UT 174 Use 1260 for all other p.eaks I Figure 9. Chromatogram Division Flowchart [ 8). Use 1260 for all peaks 81 ------- REFtRENCES: 1. “Method for Chlorinated Hydrocarbons in Water and Wastewater ’, this manual, p. 7. 2. Leoni, V., “The Separation of Fifty Pesticides and Related Compounds and Palychlorinated Biphenyls into Four Groups by Silica Gel Mlcrocolumn Chronatography , Journal of Chromatography , 52, 63 (1971). 3. McClure, V. E., “Precisely Deactivated Adsorbents Applied to the Separa- tion of Chlorinated Hydrocarbons ’, Journal of Chromatoq aphy , 70, 168 (1972). 4. “Handbook for Analytical Quality Control in Water and Wastewater Laboratories”, Chapter 6, Section 6.4, U. S. Environmental Protection Agency, National Environmental Research Canter, -Analytical Quality Control Laboratory, Cincinnati, Ohio, 45268, 1972. 5. “PestIcide Analytical ManuaP, U. S. Dept. of Health, Education and Welfare, Food. and Drug A iiinistratlon, Washington, 0. C. 6. Bellar, T. A. and Lichtanberg, J. J., “Method for the Determination of Polychlorinated Biphenyls in Water and Sediment”, U. S. Environmental Protection Agency, National Environmental Research Center, Analytical Quality Control Laboratory, Cincinnati, Ohio, 45268, 1973. 7. Goerlitz, 0. F. and Law, L. M., “Note on Renoval of Sulfur Interferences from Sediment Extracts for Pesticide Analysis”,. Bulletin of Environmental Contamination and Toxicology , 6, 9 (1971). 8. Webb, R. G. and McCall, A. C., “Quantitative PCB Standards for Electron Capture Gas Chromatography”, Journal of Chromatographic Science , 11, 366 (1973). 82 ------- APPENDIX F REMEDIAL INVESTIGATION COSTS AND SCHEDULES! REMEDIAL ACTION CONSTRUCTION SCHEDULES HUDSON RIVER PCBs SITE NEW YORK ------- Cost estimates and project schedules for the Remedial Investigation programs proposed in Section 10.0 are presented in Appendix F. Estimated pre—constructlon and construction schedules are also presented. Direct cost items and a Cost Summary Table for the Remnant Deposit Remedial Investigation described in Section 10.3 are presented on pages F—2 and F—3. Similar tables for the Phase One Remedial Investigation of the river, described in Section 10.4 are presented on pages F—4 and F—5. Pages F—6 and F—7 present estimated project schedules for the Remnant Deposit and River Monitoring Remedial Investigations. Pages F—8 and F—9 present preconstruction and construction schedules for the actual remedial activities at the Remnant Sites. F—i ------- HUDSON RIVER PCBs SITE. NEW YORK REMEDIAL INVESTIGATION. REMNANT DEPOSITS DIRECT COST TABLE (JANUARY 1983 DOLLARS) Preliminary Site Activities Activities Total Hours 1 .360 1 .430 Travel & Living $5,000 S 2.500 CLP Lab Analysis 0 36,000 Special Equipment 800 300 Subcontracts 0 13,000 Other Direct Costs 5,600 6,300 F—2 ------- HUDSON RIVER PCBs SITE, NEW YORK REMEDIAL INVESTIGATION, REMNANT DEPOSITS COST SUMMARY (JANUARY 1983 DOLLARS) Direct Labor $ 37,800 Travel & Uving 7,500 Special Equipment 1 .100 Subcontracts 13,000 Other Direct Costs 11 .900 Subtotal $ 71,300 Overhead & Profit (125% direct labor) 47.200 CLP Lab Analysis 36,000 Subtotal 154,500 G&A + Fees (20%) 30,900 Total Cost $185,400 F—3 ------- HUDSON RIVER PCBs SITE, NEW YORK REMEDIAL INVESTIGATION, RIVER ACTIViTiES DIRECT COST TABLE (JANUARY 1983 DOLLARS) Preliminary Site Activities Activities Total Hours 1,370 4,140 Travel & Living $4,600 $17,000 CLP Lab Analysis 0 88,900 Special Equipment 300 13.900 Subcontracts 0 19,000 Other Direct Costs 5,800 22,800 F—4 ------- HUDSON RIVER PCBs SITE. NEW YORK REMEDIAL INVESTIGATiON. RIVER ACTIV ES COST SUMMARY (JANUARY 1983 DOLLARS) Direct Labor $ 70,000 Travel & Living 21.600 Special Equipment 14,200 Subcontracts 19,000 Other Direct Costs 28,700 Subtotal $153,300 Overhead & Profit (125% direct labor) ‘87,500 CLP Lab Analysis 8&900 Subtotal S329,700 G & A fees (20%) 65,900 Total Cost $395,600 F—5 ------- YEAR 0NE IN WEEKS) I 1 — i ! ! J! IL !!. !!. !t I iL !! !! !2 .!! !! 1! i fl 1! 1! 1! ! ! . ii ! 1± ii 11 PRELIMINARY REMEDIAL INVESTIGATION ACTiVITiES TASK I - PREPARE RI WORK PLAN — IL Ii I1 u TASK 2 - PERFORM COMMUNITY RELATiONS SUPPORTFUNCT1ONS : = = TASK 1 - COLLECT AND EVALUATE EXISTING DATA TASK 4 - PERFORM HEALTH, SAFETY. AND GENERAL SITE RECONNAISSANCE — TASKS - SECURE PERMITS, RIGHTS OF ENTRY AND OIlIER AUThORIZATiONS • • U TASKS - PROCURE SUBCONTRACTORS — — • TASK 7 - DEVELOP SITE-SPECIFIC hEALTh AND SAFETY PLAN TASK * - DEVELOP SITE-SPECIFIC QUALITY ASSURANCE PLAN TASKS - DEVELOP SITE-SPECIFIC SAMPLING PLAN TASK 10 - MOBILIZE FIELD EQUIPMENT SITE REMEDIAL INVESTIGATION ACTIVITIES TASK II - PERFORM GROUND SURVEY — — • • • TASK 12 - PREPARE TOPOGRAPHIC MAP — TASK IS - COLLECT SURFACE S L SAMPLES TASK 14 - REDUCE AND EVALUATE DATA • • — — • — -n TASK IS - PREPARE REMEDIAL INVESTIGATION REPORT — . — — —— — — — — — —— — i_k Li CONTRACTOR ACTIVITY U _ -i PERIODIC CONTRACTOR ACTIVITY AS REQUIRED i.u ’ EPA/NYSDEC REVIEW FIGURE F-I REMEDIAL INVESTIGATION PROJECT SCHEDULE, REMNANT DEPOSITS I JUS I I _ 0 A Halliburton Company ------- PRELIMINARY REMEDIAL INVESTKATION ACTIYITI [ ..S TASK I - PREPARE RI WORK PLAN TASK 2 - PERFORM COMMUNITY RELATIONS SUPPORT FUNCTIONS TASK I - COLLECT AND EVALUATE EXISTING DATA TASK - DEVELOP SITE-SPECIFIC HEALTH AND SAFETY PLAN TASK S - DEVELOP SITE-SPECIFIC QUAUTY ASSURANCE PLAN TASKS - DEVELOP SITE-SPECIFIC SAMPLING AND ANALYSIS PLAN TASK 1 - PROCURE SUBCONTRACTORS TASK $ - SECURE PERMITS, RKHTS OF ENTRY, AND OTHER AUThORIZATIONS TASK 9 - MOBILIZE FIELD EQUIPMENT -n STE REMEDIAL INVESTIGATION ACTIVITIES TASK 10 - COLLECT DRINKING WATER SAMPLES TASK II - COLLECT AIR MONITORING SAMPLES TASK $2 - PERFORM WETLAND STUDY TASK I) - COLLECT TERRESTRIAL VEGETATION SAMPLES TASK I - REDUCE AND EVALUATE DATA TASK IS - PREPARE REMEDIAL INVESTK ATION REPORT LE GE P lO • CONTRACTOR ACTIVITY D PERIODIC CONTRACTOR ACTMTY AS 113 EPA/NYSDEC REVIEW REGJIAEO ‘ MEDIAL INVESTIGATION PROJECT SCHEDULE ‘ VER ACTIVITIES HUDSON RIVER PCB SITE, HUDSON RI ., NY FIGURE F-2 NWB COFF ORATKJN ------- WttKI 0 ACI VITY REMEDIAL INVESTIGATION WORK PLAN REMEDIAL INVESTIGAIION WORK PLAN APPROVAL RIGIITS OF ENTRY SUBCONTRACTOR PROCUREMENT DEVELOP HEALTH AND SAFETY PLAN DEVELOP QUALITY CONTROL PLAN DEVELOP SAMPLING PLAN PRELIMINARY LOCATION OF BORROW SITES OWNER CONTACT FOR PRELIMINARY BOWTOW SITES FIELD INVES lIGATION RECON• NAISSANCE OF BORROW SITES CONCEPTUAL DESIGN OF BORROW SITES GROUND/AERIAL SLIRVEYSOF REMNANT SITES SAMPLE COLLECTION-REMNANT SITES SAMPLE ANALYSISfVALIDATIOH DATA REDUCTION /EVAUJATION CONCEPTUAL REMEDIAL DESIGN ARMY CORPS PROCUREMENT FOR FINAL DESIGN SUBCONTRACTOR DESI ON/SPECIFICAI IONS ARMY CORPS PROCUREMENT FOR CONSTRUCTION COMMUNITY RELATIONS PREC()NSTRUCTION PHASE HUDSON RIVER PCB SITE, HUDSON RIVER, NY FIGURE F NUS CXJRPORAT 0 A Hallsburton Company I nc B9 90 97 9E qfl flI() Pp 11 CO CONSTRUCTION PHASE II- PLACE CONTAINMENT Of REMNANT DEPOSITS ------- ACTIV iTY PRECONSTRUCTION PHASE PRECONSTRUCTION MEETING HEALTH AND SAFETY I MOBILIZATION AT BORROW AREA ___________ CLEAR/GRUB AT BORROW AREA DEMOBILIZATION AT BORROW, MOBILIZATION AT REMNANT AT DEPOSITS, BORROW—— E*CAVATE/SIOCKPILE TOP- SOIL AT BORROW - CLEAR/GRUB AT REMNANT DEPOSITS ____________ CONSTRUCT SIORMWAtJR DIVERSION AT REMNANT fl DEPOSITS ——-—— — - (0 EXCAVATE/HAtS/PLACE — SUBSOIL AT REMNANT DEPOSITS -- - --- — - HAUL/PLACE TOPSOIL AT RIGRADE FOR RIPRAP AT NO2 AND NO.4 PLACE RIPRAP AT NOt AND NO.4——----—-—- — REVEGETATE AT BORROW - REVEBETATE AT REMNANT - DEMOBILIZATION AT BORROW DEMOBILIZATION AT REMNANT DEPOSITS CONSTRUCTION PHASE ____ FIGURE F-4 - IN-PLACE CONTAINMENT OF .. 4NANT DEPOSITS HUDSON RIVER PCB SITE. kIDSON RIVERINY I EjI\J ’ iS _________ JRATUN ------- |