United States
Environmental Protection
Agency
Region I
J.F. Kennedy Federal Building
Boston, MA 02203
&EPA
REGION I
WATER QUALITY MANAGEMENT PROGRAM REVIEW
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REGION I
WATER QUALITY MANAGEMENT P JG1W1 REVIEW
CASE STUDY
Housatonic River
Massachusetts — Connecticut
April, 1982
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Rousatonic River Basin Case Study
Table of Contents
I. Introduction /Background
A. Introduction,’7 ajor Problem t scriptions (Phosphorus, PCB’s)
B. Basin Description
1. geological — hydrological
2. socio - econanic
C. Map
II. Major Water Quality Problem Areas
A. PB’s
1. Existing Conditions
a. surface water
b. sediments
c. fish & wildlife
d. use
e. quality problems
2. Pollution Sources
a. point sources
b. non—point sources -
B. Phosphorus & Organic Loadings
1. Existing Conditions
a. surface water
b. uses
c. quality problems
2. Pollution Sources
a. point sources
b. non—point sources
UI. Water Quality Management Problem Solving Strategy
A. SEA Process — SEA ‘brking Group on the Interstate Thansport
of Pollutants
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B. PCB Problem
1. Water Programs
2. Enforcement
a. permits
b. enforcement actions
c. A.O. & study efforts
3. Survei1lance/1 na1ysis
a. nonitoring
C. Phosphorus Problem
1, Water Programs (Phosphorus)
a. construction grants
b. non—point source control
2. Enforcement (Phosphorus)
a. permits
b. pretreatment
c. enforcement actions
d. municipal menagement system
3. Surveillance/Analysis (Phosphorus)
a. nonitoring
IV. Future Activities
Appendices
I. Naugatuck River — Success StoEy
II. PCB Consent Order (5/29/81)
III. PCB Chronology (8/21/81)
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Nousatonic River Case Study
I. Introduction/BackgrCU7X i
A. Introduction — Major Problem Descriptions
The Housatonic River is located in western Massachusetts and western
Connecticut and travels in a southerly direction for 131 miles before
eventually emptying into Long Island Sound. The Housatonic River
Basin includes the urban centers of Pittsfield, Massachusettis,
Denbury, Ansonia, Shelton, Stratford, and Waterbury Connecticut. It
also flows through extremely scenic rural and forested areas in
western Massachusetts and northwestern Connecticut. Swirrming and
boating have always been popular attractions for the iitpoundments of
the Housatonic in southwestern Connecticut, activities that ceased
in MA in the early 1900’s. The river always supported an active
sport fishery. Local and visiting fishermen have fished the Housatonic
for food and sport since colonial times. rtions of the Housatonic
within Massachusetts were also known for bountiful catches of frogs.
The Housatonic River, however, suffers fran two critical but distinct
water pollution control problems: phosphorus—induced algae growth
problems in the river impoundments, and PCB contamination of river
sediments and the resulting high concentration of PCB in the river’s
fish and aquatic life. Both problems have adversely affected the
recreational potentials of the river and have caused econanic losses.
These problems are particularly cauplex because they involve an
interstate stream. The ultimete effects of some of the pollution
sources are not uniquely felt in the originating state but are often
nost serious far downstream in another state.
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B. Basin Description
The Housatonic River Basin extends 1,950 square miles across Connecticut,
Massachusetts, and New York. The waters of the Housatonic River flow
south frau Pittsfield, Massachusetts, through western Massachusetts and
western Connecticut before rptying into Long Island Sound. The total
length of the river is approximately 132 miles. Major tributary rivers
include ‘I n Nile River (portions in New York), Still River, Shepaug
River, and Naugatuck River.
Over half of the basin’s population resides in the major urban areas
around Pittsfield, Massachusetts, in the north, and t nbury, Waterbury,
and Stratford, Connecticut, in the south. C*itside these urban areas
the basin is largely undeveloped; forestry, agriculture, and recrea-
tion predcininate. Many of the basin’s unique ecological features and
recreational opportunities center around the narrow, steep—walled
valley of the Housatonic River.
The Housatonic’s origins are scme of the picturesque Berkshire County
lakes near Pittsfield, MA. Approximately five miles south of
Pittsfield the river backs up behind the Woods nd Darn. The dam
originally built to power a paper plant is no longer utilized for
that purpose • The dam does serve to form a large sediment trap
which has over the years caused heavy sludge accumulation and nutrient
retention. The pond is in an advanced eutrophic stage and has lost
much of its appeal as a recreational water body. The Woods nd Dam
has also served to trap PCB laden sediments transported frau upstream.
It has been estimated by the cr DEP that 70% of the total quantity
of PCB contaminated sediments in the Housatonic are resting behind
the Woods nd Dam.
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After flowing thrcugh the urban industrial centers of Lenox and Lee,
MA, the HousatoniC winds through picturesque southwestern Massachusetts
and past the popular tourist areas of Stockbridge and Tanglewood.
The Housatonic Main Stein Basin fran the cr — MA State line to the
confluence with the Naugatuck River at Ansonia is primarily rural in
nature and is a favorite recreational river in the State. Portions
of the Housatonic near Cornwall, Connecticut, were considered one of
the very best trout fishing areas in New England.
The Housatonic River is distinctive in Connecticut in that there are
hydroelectric dams along the main stein of the river of which three
form major lakes: Lake Lillinonah, Lake Zoar, and Lake Housatonic.
The Housatonic and Naugatuck Rivers join 13 miles upstream fran the
muth at Long Island Sound.
The Naugatuck River, the Housatonic’s nost i ortant tributary, has
historically been known for extremely poor quality. Extensive
pollution control efforts have resulted in a clean—up success story
for the Naugatuck. (See story in Appendix I).
Water pollution, flooding, the management of waters and related lands
for recreation, and projected deficits in water supplies are all
problems that need to be resolved in the basin. In the following
paragraphs the major issues and problems confronting the Housatonic
River basin are presented.
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1. Water Supply
The basin supplies 136 million gallons of water per day to its resi-
dents and various industrial users through 154 public water supply
systems and an out-of—basin diversion to the Bridgeport Hydraulic
Company System in Connecticut. By 1990, these supplies will not be
able to meet the increasing demand in 22 basin towns. The i ost
serious shortages will occur in the Pittsfield, Danbury, and lower
Naugatuck River areas. In some cases, proposed solutions, such as
the Washington Mountain Brook PL—566 project in Massachusetts and
the proposed Shepaug River diversion in Connecticut, have created
considerable controversy.
2 Water Quality
Water pollution is a serious problem in the Housatonic, Still, and
Naugatuck Rivers and to a lesser extent in the 1 n Mile River in
New York, primarily as a result of inadequately—treated municipal
and industrial wastes and combined sewer overflows. These discharges
not only affect river segments immediately downstream of disposal
sites, but also contribute phosphorus, which accelerates eutrophica-
tion, to run-of—river lakes used for recreation (such as Zoar and
Lillinonah). Waste discharges in Massachusetts and possibly in
New York adversely affect the quality of the Housatonic River in
Connecticut.
PCBs have been found in the water and in the sediments from the
bottom of the Housatonic River from Pittsfield south to Darby.
PCB discharges fran the major source, the General Electric Plant
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in pittsfield 1 have been stop d (NPi S allows about l0ppb to be
discharged — about 10—15 pounds/ncnth); however, PCBs continue to
enter the river fran landfills, storm runoff, and sediments.
Both Connecticut and Massachusetts have issued health notices
warning peop].e not to eat fish taken fran the
Housatonic River; the Massachusetts health warning also included
frogs and turtles. Some plans have recommended that riverside
aquifers be used to enhance water supplies in the basin; however,
concerns exist that pumping wells may draw PCB contaminated
river water into the aquifers. To date, however, no contamination
has been reported at the extensive Shelton well fields of the
Bridgeport Hydraulic Company which currently are recharged with
Housatonic River water. A USGS study in Massachusetts will
provide additional data on the potential for PCB contamination
of ground water.
In 1979, the Enviro inenta1 Protection Agency (EPA) established a
rking Group on Interstate Transport of Pollutants, composed of
representatives fran Massachusetts, Connecticut, and New York,
to help resolve interstate water quality problems. For the
Housatonic basin the Group has coordinated pollution control
efforts for phosphorus and BS. The rking Group has assumed
responsibility for the developTent of a comprehensive and coor-
dinated strategy for resolving the problems of PCB contamination
and for identifying resources available through various agencies
to help it carry out its rk .
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3. Flooding
There are severe problems of coastal flooding and erosion in the
basin which, at the river’s n uth, reduce the recreational poten-
tial of coastal and beach resources. Federal agency studies have
determined that federally—assisted projects are not feasible,
but the State of Connecticut, through its Coastal Area Management
Program and FlOOd Control and Beach Erosion Program, is continu-
ing to assist coastal towns in developing approaches to managing
their flood prone and erodible coastlines.
4. I creation and Wild and Scenic Rivers
The water resources of the basin are used for recreation in the
upland lakes in the northern basin, in Candlewood arid run-of—river
lakes such as Zoar and Lillinonab in the southern basin, along the
Shepaug and Housatonic Rivers, and in the coastal areas. Although
additional facilities are needed to meet the demands for recrea-
tional uses — particularly swimming — the proper management of
recreational resources in the basin is of greater concern.
Areas around the upper Housatonic River in Connecticut and the
Shepaug River are noted for their outstanding cultural and
natural features: scenic nountains and valleys, productive
wildlife habitat, rare ecological areas, and a variety of
recreational opportunities. Forty-one miles of the upper
Housatonic and 26 miles of the Shepaug qualify for inclusion
in the National Wild and Scenic River System.
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It is widely recognized that the rivers of the basin need to be
protected fran incanpatible uses. A major concern of those
dealing with the problems of the Housatonic is the nature of
riverside development. Northeast Utilities has put forth a
proposal to develop sane of its riverside land for recreation
(a condition of its hydropower license) which has caused con-
siderable controversy. Part of the controversy stems from the
fact that area towns fear that the increase in the use of the
river would canprcinise the natural environment in which recrea-
tion is now pursued. A major concern of those dealing with the
problems of the Shepaug River is the demand for water to be
diverted fran the Shepaug to adjacent areas in need of in-
creased water supplies.
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Socio-Econanic Characteristics
l.B.2
O In 1975, a population of 732,609 resided in the Housatonic Basin (83% in
Connecticut; 14 percent in Massachusetts; and 3% in New York).
o Average density of population in 1975 was 376 people per square mile,
catpared to Statewide averages of 704 for Massachusetts, and 618 for
Connecticut.
O Population in Massachusetts and New York portions decreased between 1970
and 1975. The Connecticut portion has shown increased population growth
rate.
o 1970 p1oyment Massachusetts Connecticut
manufacturir 50% 35%
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r mont
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*
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S 1ngfi1d
Stream Segments
• , Lass than Class B (fishable’
swimmable) Quality
‘/‘ Water Quality Limited*
C’ Lakes and Ponds: Water Quality
Problems
Numbers refer to Table 12
*(Mec4ures beyond best practi-
cable or secondary treatment will
be needed to meet state stan-
dards)
Sources:
CT DEl’, 305(b. 1978 (3105)
CT DEl’. 303(e), 1975 (3101)
CT DEP, 303(e) Phase 11 Draft,
1979 (3107)
NY DEC. 303(e). 1977 (3106)
MA DWPC, 305(b, 1978 (3122)
BCRPC. 208. 1978 (3102)
MA DEQE. Lakes 1976c (3118)
MA DEQE, 303(e) Part D. 1975
(3125)
-rJ
A lbwiy
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II . Major Water iality Problem Areas
A. P s
1. Existing Conditions
The existing water quality classification of the Housatonic River
was downgraded fran Class B to D when it was discovered that PCB
(Polychiorinated biphenyl) concentrations in Housatonic River
fish exceeded limits set by the U.S. Food and Drug Administration.
The PCB concentration varied fran nore than 40 ppm to less than
one part per million in fish. The FDA limit is 5 ppm. In 1977, the
Connecticut r partment of Health placed a health advisory against
eating fish fran the Housatonic. PCB contamination will prevent
109 miles of the Housatonic (nearly the entire main stem) fran meeting
the 1983 fishable—swimmable goals of the 1977 Clean Water Act.
A study initiated by Connecticut reported that PCBs were found to
have accumulated in the Housatonic River wherever sediment had
accumulated • Fran the Stevenson Dam in Connecticut the concentra-
tion of PCBs in these sediments increased gradually with increas-
ing distance upstream, and then increased sharply in Woods Pond,
the first impoundment below Pittsfield, Massachusetts. The PCB
concentrations found in the sediments ranged f ran less than 1 ppm
in Lake Zoar to greater than 50 ppm in Wood’s Pond. The distribu-
tion of PCBs within an impoundment was found to be controlled by the
distribution of fine-grained sediment.
Sediment sax les taken above Pittsfield, in the Ten Mile River in
Connecticut, and in several lakes in Connecticut showed only typical
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background concentrations of 0—0.1 ppm. Six samples from the
Still River, a tributary in Connecticut, contained an average of
0.33 ppm, with Aroclor 1248 predominating. The ratio of Aroclor
1248 to Aroclor 1260 was higher in salTples from Lakes Zoar and
Lillinonah than in samples collected upstream, suggesting that
sane PCBs entered these lakes from the Still River. Differential
transport of P roclor 1248 downstream may also have occurred. Actual
transport of PCBs by suspended sediment is still under study.
Calculations of the mass of Bs in the sediments in the river
suggest that of the estimated total of 22,200 ].bs, about 60% is
still located in Massachusetts with nearly all of this anount in
sediments in Woods Pond. About 40% of the total mass of PCBs is
in the sediments in Connecticut: about 29% is in Lake Lillinonah
and 10% is in Lake Zoar with small anounts at other locations.
In conclusion, it appears that the principal source of PCBs in
sediments of the Housatonic River in Connecticut is the PCB
contaminated sediment from Woods Pond in Massachusetts. Because
the only known user to date of large anounts of PCBs was the
General Electric Ccxpany plant in Pittsfield, leakage from the plant
to Woods Pond seems the likely source of Aroclors 1254 and 1260 in
impoundments in Connecticut. The source of Aroclor 1248 is not
known at this time.
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II.A.2 Pollution Sources (PCBs )
A major problem in the Housatonic fran Pittsfield through Lake Zoar
is the presence of high levels of polychlorinated bJ.phenyl (PCB)
canpounds. These were discharged fran the General Electric plant in
Pittsfield fran the early 1930s until 1977 and now continue to enter
the environment fran landfills, runoff and sediments, and in very
low quantities fran continuous GE discharges. Since KB ccrtpounds
have low solubility, they do not significantly affect water quality.
Ibwever, they have beccine concentrated in fine —grainS bottan sediments,
enter the food chain, and accumulate in fish tissue at levels much
higher than the maximum tolerance level set by the Food and Drug
Administration (currently 5 parts per million (ppn)]. As a result,
both Massachusetts and Connecticut have issued public health warnings
against the consumption of fish taken fran the river, and Connecticut
DEP has downgraded its classification of the existing water quality
of the river fran a B 5 (fishable—swimnable) to a D (nonfishable).
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fl.B. Phosphorus and Organic Loadings
1. Existing Conditions
Water quality problems due to conventional municipal and industrial pol—
lutants is the Housatonic Basin have been recognized since the late 1800’s.
As early as 1884, Henry Parker Fellows, in his book “Boating Trips on New
England Rivers” wrote about discoloration and and odors in the Housatonic
due to refuse emanating fran the mills. The first extensive water quality
survey was conducted in 1936 by the Works Progress Mministration which re-
sulted in a Massachusetts Senate act reccnnending corrective action. Another
survey conducted in 1949 found conditions to be worse and the Massachusetts
Senate again passed a resolution calling for clean—up of the Housatonic River
This scenario was repeated several times before significant remedial action
was initiated.
A 1971. report by the Massachusetts Division of Water Pollution Control
(MØ. JPC) based on a 1969 intensive water quality survey stated that discharges
fran Pittsfield and General Electric in Pittsfield required “tertiary treat-
ment” if dissolved oxygen standards were to be met. Mditionally the MIiI PC
noted high concentration of phosphorus in both the Pittsfield and GE effluents
and concluded that the phosphorus levels would have to be reduced if the River
were to becane usable again.
The 1969 survey was the first Ebusatonic survey in Massachusetts to con-
sider the impacts of nutrient discharges and subsequent algae growth. Three
impoundments of the Housatonic, Center Pond in l lton, Woods Pond in Lenox
and Rising Pond in Great Barrington were all identified as being eutrophic.
Woods Pond, i tmediately downstream of Pittsfield and GE was further described
as a “waste assimilation” system for the upstream discharges. SQlids, organic
materials, nutrients, and coliform bacteria were all present in excessive
anounts rendering this shallow iznpoundnent virtually useless. Continuous
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nonitoring of dissolved oxygen showed extrele variations between day and
night values due to overabundant planktonic algae photosynthesis and respira-
tion. The periodic rapid die-off of the large algae population lead to odor
and sediment problems further exacerbating the polluted condition of ods
Pond. Subsequent National Eutrophication Study and M1Y.’ PC reports on Woods
Pond show that these conditions continue. Qi the other hand, the high pro-
ductivity of the Pond make it an ideal comunity for certain tolerant warm
water fish, frogs, and turtles as well as a highly regarded waterfowl habitat
and hunting area. That is, until it was discovered that the I nd was not only
the recipient of routine municipal and industrial wastes, but had had its
sediments, aquatic life and waterfowl contaminated by high levels of PCB’s.
At the same time Massachusetts was examining the impacts of wastewater
on the Housatonic, the Connecticut DEP was investigating nuisance conditions
in the three major Housatonic impoundments — Lakes Lillinonah, Zoar, and
Housatonic. The Connecticut I gricultural Experiment Station (CAES) in 1968
and 1969 carried out nutrient budget studies. These detailed studies were
supplemented in 1972 and 1973 by NEI work. Both of these studies indicated
that the Housatonic River was a major source of phosphorus to the lakes and
that MA discharges constituted about one—half the phosphorus in the
Housatonic at the beginning of the lakes. A 1976 303(e) basin plan prepared
by cr DEP recaTlilended that MA should go forward with plans for phosphorus
control at Pittsfield and GE, the two largest phosphorus sources in IA.
Based on the findings of the 1969 survey, the City of Pittsfield began
planning for expansion and upgrading of its treatment facilities and GE
started making provisions for further treatment of its wastewater and for
reducing the anount of phosphorus used in their manufacturing processes. In
addition, nost of the other smaller municipal and industrial discahrgers
installed treatment facilities or upgraded to secondary during the 1970’s.
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In 1974 another Massachusetts water quality survey documented slight
improvements in water quality but found continuing problems below Pittsfield.
While GE had cut is phosphorus loading by 50%, Pittsfield was still discharg-
ing large amounts of phosphorus. Eutrophication problems were identified in
the Sheffield meanders (about 40 miles downstream of Pittsfield and 10 miles
above the Connecticut state line) as well as Woods Pond. At this time, the
M1] JPC concluded that phosphorus fran the Pittsfield treatment facility was
the likely cause of the problem but that the relationship between Pittsfield’s
phosphorus and the Housatonic’s eutrophication problems were not fully
understood.
Meanwhile, the CAES in 1973 and 1974 documented highly enriched waters
in Lakes Lillinonah and Zoar. The resultant bluegreen algae bloans were
inhibiting recreational uses of the lakes as well as causing dissolved
oxygen depletion. The CT DEP enlisted the aid of the EPA National Environ-
mental Investigation Center out of Denver to perform algae assays on Lake
Lillinonah, the ncst upstream impoundment. These studies confirmed DEP’s
suspicions that phosphorus was the limiting nutrient for the nuisance algae.
Based on this information and the phosphorus loading data calculated earlier,
er CEP and FMC Corporation conducted a two-year study of phosphorus renoval
at Denbury — the largest Connecticut source of phosphorus. This study
showed that phosphorus retoval was technically feasible on a large scale and
concluded that Denbuzy should seasonally renove phosphorus. Further, the
study recannended that additional data be collected on the Massachusetts
sources, particularly Pittsfield, since phosphorus remDval fran only the
Connecticut sources uld possible allow nuisance conditions to continue.
Massachusetts and Connecticut both agreed that before Pittsfield, or any
other source of phosphorus in Massachusetts, could be ordered to renove
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phosphorus, that the benefits of this r oval would have to be firmly estab-
lished. Connecticut DEP urged EPA and MA I PC to study the phosphorus
transport fran MA into CF and to develop orders, where necessary, to control
this nutrient and hopefully the eutrophication problems in CF.
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III. Water iality Management Problem Solving Strategy
A. The SEA Process - The SEA Working Group on the Interstate Transport
of Pollutants.
Several important interstate streams in New England have received
pollutant loads from out of State sources that cause severe water
quality problems. EPA and the States of Connecticut and Massachusetts
negotiated State/EPA Agreements (SEA) issues with the intent of
providing the critically needed high level of cooperation and coor-
diriation of pollution control efforts for 3 high priority water
resources between Connecticut and Massachusetts (Housatonic River,
Connecticut River, French River). An SEA Working Group on the
Interstate Transport of Pollutants was formed to assist in the dis-
semination of technical infonnation to the various State, Federal
and local officials involved, and to coordinate the efforts and
maintain an open, direct channel of ca munication between all
parties.
EPA Region I took the lead role in coordinating the input and
participation of the States of Connecticut, Massachusetts and
New York, EPA Region II, the Corps of Engineers, and the New
England Interstate Water Pollution Control Cc nnission. Various
representatives of local government, 208 planning agencies, local
media and the public often attend the Work Group meetings. The
excellent working relations and the spirit of cooperation engendered
and supported by the SEA working group efforts have helped to
promote progress in ovecoming some particularly complex problems
on the Housatonic River.
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Although the SEA Issue project n nagement rests with the Water
Division, a great deal of effort and cooperation has been provided
by the Enforcement Division (both Permits Branch and Enforcement
Branch), and the Surveillance and Analysis Division.
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III. Li. Water Division (T(B’s )
Until 1981, EPA did rot play an active role in resolving the
PCB problems in the Rousatonic. Fran the early 1970’s to 1981,
EPA ’s role consisted of participating as an “ex—officio nether
of Connecticut’s ECB Program Guidance Conmittee. Since the mid
1970’s, the Water Division played the lead role within EPA con-
cerning the resolution of the Housatonic River PCB problems. The
reason for the Water Division’s lead role was primarily because it
was felt that the PCB’s were an in—stream water quality problem and
not a case of storage or handling of PCB’s which were under the
purview of TSCA. Water Division staff was designated as the EPA
representative to the Housatonic River Program Guidance Canm.ittee
(PCB-PGC). The PCB-PCC was formed by Connecticut to guide the
studies funded by a special $200,000 appropriation by the Connecticut
Legislature. The studies funded by Connecticut include: a sediment
study including locations and concentrations of hot spots; a fish
tissue study; and a human blood serum study. Through this phase
EPA’s role was primarily advisory; the EPA S&A labs also performed
sane nonitoring activities during this period.
As the Connecticut studies (and funds) neared caripletion, Connecticut
sought a nore active role by EPA and Massachusetts. The 1979 SEA
issue on the Interstate Thanspart of Pollutants sought to elevate
the priority of this, and other interstate water quality problems,
and help focus additional resources on these areas. Since 1979,
the Housatonic River (ECB’s and Phosphorus) have taken. on increas-
ing emphasis in the SEA process. Water Division Staff continue to
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provide project management for this SEA issue and therefore maintain
a leading role in the coordination of State and Federal efforts in
this area. The items listed below show current Water Division
activities:
(IM, B) — Provide project management for SEA Issue on the Interstate
¶ftansport of Ikllutants
(IM) — Schedule SEA ‘brk Group Meetings and provide agenda
(IM) — chair and lead SEA WDrk Group discussions
(IM) — Suitunarize SEA brk Group discussions and highlight “actions
needed”; distribute to all participants
(IM, B, — Provide technical guidance to EPA Enforcement Division on
1MB) dministratiVe Orders with
(IM) — Participate in meetings of Connecticut’s PCB Program Guidance
Canmittee
(IM) — Prepare coordinated responses for PA on nost Housatoflic related
correspondence fran State agencies and congressional offices
(NB) — Provide technical guidance to Enforcement Division and S&A
relative to groundwater contamination
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111. B.2. Enforcement Division (KB’s)
a. Fflforcenent Branch
The General Electric Canpany is in the process of ccznplying with
the July 1981 consent order requiring reporting on PCB disposal
practices and studies of the Ibusatonic River. For background on
the Order, appended to this m o is a ccpy of the Executive Sunriary
which was sent by Region I to the EPA Administrator, and a copy of
the mern frau Larry Coidman, former Enforcement Division Director
to the Regional Administrator including a chronology, an outline
of the tasks required by the Order, and maps.
Since the order was issued, G.E. has suti’nitted the required
proposals. After two highly satisfactory meetings with G.E.,
its consultants, and personnel fran MA DEQE and cr 1 P, EPA and
DEQE approved the proposals, with the concurrence of er DEP. A
letter fran EPA dated December 17, 1981, recorded two changes
which had been agreed to. January 12, 1982, after sane
extensions in the deadlines, G.E. subuitted its report on past
disposals practices. Under its approved schedule, the study of
}iousatonic PCB’s will be caupleted by Decenter 1982, and the
Woods Pond remedial action study by the Spring of 1983. There-
after EPA, DEQE and DEP will have to evaluate the results and make
decisions, possibly difficult ones, concerning further action.
The Region is optimistic that solutions to this problem will emerge,
and we will be able to restore the river to fishable quality within
a few years. I oreover, the spirit of the people involved, parti-
cularly G.E., Stewart Laboratories, Steve Joyce of DEQE, and the
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Berkshire County Regional Planning Canmission, pramised to make
this an open and cooperative effort.
Other possible sources of PCB’s in the Housatcnic have been investi-
gated by EPA under the Versar contract. &m e TSCA violations have
been found, and enforc tent action is being considered at sane
sites, all in Connecticut along the lcMer part of the river. Final
decisions about these violations have not been made. At this time,
it does not appear that any of them represent significant sources of
PCB’s in the river. EPA hopes to visit two or three remaining sites
in the Spring under the Versar contract, but we do not expect to
find significant releases into the river.
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—22—
III.B. 2.
b. Permits Branch
rcB’s — General Electric Co .
The PCB issue was addressed in a 2/3/78 ITodification to G.E. ‘s original
NPDES permit *MA0003891. The original permit and ITodification both
expired on 12/1/80 and are presently being considered for reissuance.
G.E. was required to implement a control program to reduce effluent PCB
levels at outfalls 005 and 006 to weekly averages of 0.055 lbs/day and
0.023 lbs/day and weekly maxiinun of 0.170 lbs/day and 0.070 lbs/day,
respectively by april 1, 1979. These limits were achieved by the imple-
mentation of a multi phase program including discontinuation of PCB
usage, pipe relining, excavation, construction, oil/water separator
upgrading, and other “housekeeping measures.”
The ca pany was further required to annually report on the possibility
of further PCB effluent reductions through the use of all available
technologies. G.E. has indicated in its 1979 annual report that certain
technologies are available to further reduce PCB levels but requested
that EPA wait until the existing construction and housekeeping had been
caiipleted for a sufficient “stabilization” period to a11c for an ade-
quate assessment of the work already canpieted before any further permit
requirements were imposed. EPA agreed to this in March of 1979.
The Permits Branch is ri reviewing the reapplication. If it is deter-
mined that further treatment is needed, the forthcaning “BAT” permit
will include these requirenients.
EPA Permits Branch recently (2/82) issued a permit to GE to incinerate
PCBs at the Pittsfield facility. The GE incinerator was built specif i—
cally for incineration of PcBs.
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—23-
III.B.3. Surveillance and Analysis DiviSion (1 Bs )
In 1972 when the hazards of PCB’s first became suspect, S&A conducted
an industrial sampling program at the General Electric Cat any, Pittsfield,
Massachusetts, to determine if they were discharging PCB’s to the Housatonic
River. In conjunction with this, a series of river stations were also
sa 1ed. This early work confirmed that PCB’s were being discharged to the
river, but the extent of the problem was not known.
In 1975 when hearings and litigation brought RB’s into national prani-
nence as a major pollutant, the Surveillance and Analysis Division began
looking at further PCB contamination in the Housatonic River. brking with
the Massachusetts Division of Fish arid Wildlife, water, sediment, and fish
saiçles were collected and analyzed for PCB’s. This early in 1976, the
Region and States were made aware that PCB’s were affecting sediment arid
fish populations downstream frau Pittsfield, Massachusetts. The area of
major concern at this point was the impoundment known as bods Pond in
Lenox, Massachusetts. Also, early in 1976, further saiçling was conducted
to confirm the discharge of PCB’s frcmi General Electric to the East Branch
of the Housatonic River.
These initial studies contributed to the State of Connecticut becaning
nore involved with PCB’s in their portion of the river. These studies led
to Connecticut’s issuing of an “advisory warning” on the taking of firifish
for human consunqtion fran what had been described as “the best trout fishing”
stream in the State.
Additionally, the early PCB work in this river basin and the preliminary
identification of WDods Pond as a major PCB sink led to the awarding of a
contract to examine the extent of the contamination in Woods Pond and sug-
gested remedial actions.
These issues continue to be examined through the EPA/Connecticut!
Massachusetts SEA process.
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-24—
III.C.l Water Prc rains (Phosphorus )
In the late 1970’s, the M 1 1PC concluded that phosphorus frau the Pittsfield
treatn nt facility was the likely cause of the downstream eutrophication problems
in the Housatonic. However, the relationship between Pittsfield phosphorus and the
Housatonic eutrophication problems were not fully understood. Before Pittsfield
could be ordered to renove phosphorus, the benefits of this renoval would have to be
established.
Agreements between the water quality branch and enforcement staffs of both EPA
and M]YIJPC resulted in a nodification to Pittsfield’s NPDES permit. Pittsfield
was required to renove phosphorus during the sunuuer so that a joint EPA-ME PC
intensive surveycould evaluate the impacts of phosphorus reitoval. The Connecticut
Department of Environmental Protection (CT DEP) had also surveyed its portion
of the Hoüsatonic River with particular attention paid to the major recreational
impoundments on the mainstein. 1 sidents near the impoundments and recreational
users had been canplaining in greater frequency that algal bloans were restricting
use of the impoundments and were beccining increasingly severe. It was not
clear to the Connecticut Department of Environmental Protection whether the
smaller, instate sources of phosphorus were the cause of the problem or whether
it was carryover fran the distant (70 miles) Massachusetts discharges.
Based on the 1978 survey a draft NPDES permit was sent out for public
notice with the requirement that Pittsfield practice phosphorus renoval to 1.0 mg/L
each year fran April through October. Many canments were received on the
permit and based on a request frau the City of Pittsfield, a public hearing
was scheduled for July 9, 1980. !I stimny was heard fran residents near the
Connecticut impoundments who believed that phosphorus should be renoved regardless
of denonstrable benefits.
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—25—
H ever, testinony by the Berkshire County Regional Planning Convttission 208
Agency indicated that nonpoint sources in the southern Massachusetts and northern
Connecticut portion may be contributing to the problem. There were claims
made that even if Massachusetts point sources were eliminated, there would be
enough phosphorus fran nonpoint sources to lead to continued problems in the
Connecticut impoundments. In addition, there were many canmenters who felt
that the fate of the phosphorus in the 70 miles between the discharge and
their impoundments was not well understood. Further, the City of Pittsfield
described the high cost of chemicals and sludge handling/disposal associated
with phosphorus r ioval,
The EPA Water Quality Branch ,after considering the testinony and data received
at the hearing, reccxtmended to the Enforcement Branch that permanent seasonal
phosphorus reiroval could not be technically supported without additional data
The B and the MIi’JPC agreed that further studies were necessary and that the
basin in both Connecticut and Mass, should be studied simultaneously.
At about this time, due to a high level of concern on the part of Connecticut,
it was decided to make the phosphorus loadings and impacts an SEA issue with both
Connecticut and Massachusetts to insure cooperation in all studies and mutual
agreement in all decisions. Through the SEA process, both States and EPA were
able to carbine forces and carry out simultaneous intensive studies of phosphorus
sources and instrean impacts f ran May through September, 1981. Also through
the SEA process, assistance was received fran USC Cf low), USDA (nonpoint source),
and Berkshire County RPC 208 (storm runoff). The 1981 surveys were conducted
with no phosphorus rerroval at Pittsfield and with phosphorus reitoval at the
Danbury STP in Connecticut. Mditional cooperative surveys are planned for 1982
with Pittsfield renoving phosphorus. After the data f ran both of. these
studies are available, a decision on permanent, seasonal phosphorus renoval
at Pittsfield will be made.
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—26—
It is expected that the data analysis and establishn nt of Pittsfield’s
NPDES permit limits will be done utilizing the SET process. O.iarterly, all
of the involved parties neet to discuss the progress and needs of the surveil-
lance an1 analysis, NPDES permits, construction grants, nonpoint source
planning, and interagency cooperation. This process has resulted in a high
level of interaction ai ong several agencies in both states as well as bringing
together three Divisions and the R ’s office in the Regional Office. The
caibined efforts of the Regional Office has brought praise fran both states.
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—27—
III.C.2. Enforcenent Division
a. Permits
1) Phosphorus — City of Pittsfield
The present NPDES permit #MA0101681 for the City of Pittsfield requires that
the City meet effluent limitations of 1.0 mg/i monthly average, 1.0 mg/i
weekly average, arid 1.5 mg/i daily maximum during the period April 1, 1982
through October 1, 1982 only. Exiring this time period, further stream
studies will be conducted in an attempt to conclusively denonstrate the
ijipacts of P removal by the City on the river quality, particularly in the
impoundments downstream in Connecticut. The permit also contains a reopener
clause to allow EPA to revise the permit to include effluent limits, ca i—
pliance schedules, and/or other provisions should the future stream studies
demonstrate that P removal by the City is necessary to achieve water quality
standards in the Housatonic River. The M JPC has provided certification
under Section 401(a) of the Clean Water Act that the above conditions are
necessary to satisfy the Clean Water Act requirements of Sections 208(e),
301, 302, 303, 306, 307, and 40 CFR 124.53.
It is noted that the need for P removal has been a longstanding, contro-
versial issue and has been questioned by the City and the 208 planning
agency on cost,4)enef it grounds.
2) Phosphorus — General Electric Co .
Phospborus is not regulated in the existing permit. The ccxnpany has requested
that if a P limit is to be established in the new permit, that a “bubble
concept” be employed, i.e. limit the P loading fran the entire facility
rather than outfall by outfall. This requirement will not be imposed until
further stream studies are conducted to justify the need. (See Item 1).
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—28—
It is noted that neither BPT, BCT, or BAT for this industry type presently
requires P reioval.
b) Pretreatment — City of Pittsfield
The NPDES permit requires the City to develop and imp1 nent a pretreatment
program and to sub it the program fpr approval by March 1, 1982. Whether or
not controls on industrial inputs of phosphorus are to be implemented will
depend on the outcane of the river survey and P relToval issue referenced
above. Another possible outcme of the pretreatment program could be the
imposition of controls on the industrial input of phenols as necessary to
allow the City to ccrnply with the phenol effluent limitation in its NPDES
permit.
The City’s permit does not limit PCB’s since the City’s outfalls presumably
do not contain this pollutant. Therefore, the pretreatment program would
not be concerned with the PCB issue.
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—29—
III.C.3. Surveillance and Analysis Division (Phosphorus )
Since EPA’s inception in 1970, water quality problems in the Housatonic
River have kept the Region I Surveillance and Analysis Divsion (S&A) involved
with the Massachusetts and Connecticut State Agencies responsible for their
respective reaches of the river. Most of the water quality problems have
manifested themselves in Connecticut’s portion of the Housatonic River;
howwever, major contributors to the pollution problems in Connecticut lie
on the Massachusetts side of the border.
Over the years, the Surveillance and Analysis Divsion has participated
with the State governments in developing a data base for water quality planning
activities. In 1973, at the request of Connecticut, the S&A Division conducted
a water quality study of the Housatonic River to document the effects of
nutrients in Lake Lillinonah and Lake Zoar, two iiT poundments which are used
extensively for recreation. In conjunction with that study, dye studies were
also performed in the tidal portion of the river for time of travel and dis—
pers ion analyses.
In 1978, S&A again joined forces with the States of Connecticut and
Massachusetts. Crews working with personnel fran each state conducted water
quality studies in the Housatonic River fran Pittsfield, Massachusetts, to
Lake Lillinonah in Connecticut during early and late sununertime periods.
The data collected fran these studies were to be used for verifying a mathe-
matical mdel of the river. The itodel, in turn, was to be used for estab—
lishing 1DL’s to the river.
Fran 1975 through 1980, the Connecticut Department of Environmental
Protection (DEP) conducted nutrient studies on various sources and tribu-
taries to the Housatonic River as well as lakes studies in Lake Lillinonah
and Lake Zoar, trying to establish cause and effect relationships between
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—30—
loads and summer algal blooms in the lakes. In 1981, Connecticut approached
Massachusetts and EPA, 1 gion I, about performing a study of phosphorus levels
in the Housatonic River fran Pittsfield, Massachusetts, downstream to New
Milford, Connecticut (Lake Lillinonah). The study was designed to show if
phosphorus sources, primarily the Pittsfield 1W, are the major contributor
to the nutrient problem in the Connecticut lakes. S&A crews, jointly with
Connecticut DEP personnel and coincidentally with crews from the Massachusetts
Division of Water Pollution Control, sampled the Housatonic River tributaries
and discharges during the n nths of May, June, July, August, and September.
Preliminary results have shown a large phosphorus load emanating from Hassa—
chusetts. Presently, data analyses are ongoing to isolate the origin of the
loadings, and plans are being developed to perform further joint studies during
the sunnrier of 1982.
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—31—
IV. Future Activities
A. B Problem
Through the FY82 SEA process, Connecticut, Massachusetts and EPA
designated the SEA working group as the primary coordination
mechnanism between EPA and State efforts concerning PCB’s in the
Housatonic River. The Camdssioners of the MA DEQE, Cr DEP and
the EPA RA agreed to meet periodically as a policy group to review
progress, evaluate program strategies, and redirect efforts, if
necessary. Major activities:
O SEA working group meets on a quarterly basis to provide
coordinating and reporting mechanism for PCB efforts.
o PCB policy group (Ccinmissioners, RA) meet periodically (or as
required) to direct agencies’ efforts.
O EPA Enforcement takes lead agency role in nonitoring of A.O.
with G.E.
O EPA reviews A.O. study results. 1 vise A.O. in conformance
with study findings.
B. Phosphorus
o Continue to track progress and exchange information through the
quarterly SEA process.
o I iring 2/82 EPA—WQB,CT DEP, y,qpC review 1981 river data to decide
what level of sampling is neeeded for 1982. Decide whether seasonal
P—renoval will be required at Pittsfield during 1982.
o Organize and execute sampling program during sunner 1982.
o Assess basinwide impacts of Pittsfield P—renoval. Based on these
results make recanmendations for Pittsfield NPDES permit.
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Office of
Water
Planning
and Standards
M zz.
I
U.S. Environmental Protection Agency
Washington, D.C.
20460
A Water Quality Success Story
THE X UGATUCK 1ID LOWER BOUSATONIC RIVERS
For veil over a hundred years, the fast—flowing Naugatuck
River, a viajor tributary to the Eousatonic River in western
Connecticut, supplied vaterpower to the factory towns which lined
its shores.
In 1950, the scenic valley through which the Naugatuck passes
was one of £nerica’s largest producers of nonferrous wetals and
rubber products. By then, state water quality experts called the
Naugatuck Connecticut’s west polluted river.
Twenty years later the Waugatuck was
a State of Connecticut sanitary engineer
exaggeration: ‘When I cawe here in 1970,
annihilated. There wasn’t even any grass
were no fish, no insect life, nothing.”
What happened over the years?
indeed so degraded that
could say without
the river was totally
on the banks • There
Let’s start at Torrington, sow. 37 wiles above the point
where the Naugatuck eventually flows into the Lower Bousatonic
River at Derby.
Torrington wanufactures brass products and wachine tools.
Below Torrington there’s Thowaston. Thowuton wakes brass,
cutlery, autowatic sachinery, and clocks.
Farther downatruw there’s Waterbury, ovu for its brass
products, autowatic aachinery, wetal wanufacturing, and textiles.
Doworiver is the Borough of Naugatuck. Naugatuck turns out
rubber products and chenicals. Then cowss Seywour with its
wachins tools and brass articles.
Environ mental
EPA Information
3/78
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—2—
Ansonia appears next with its brass and copper products,
foundry products and Iron casting., followed by Derby which
manufactures brass, copper, and bronze products, textiles, and
automobile and airplane parts.
All in .11, close to 40 miles of Naugatuck River packed with
37 industrial concerns, many of them wetalforming and
electroplating plants, all of which discharged untreated
industrial wastes including toxic zinc, copper, cyanide and
cadmium into its waters, killing fish and aquatic life in the
Naugatuck and in the 13—nile—long Lower Housatonic River from
Derby down to Long Island Sound.
As industry grew, so did population. Between 1950 and 1970,
for example, the populations of Thomaston, the Borough of
Naugatuck, and Beacon Falls alone grew by 27, 32, and 72
percent, respectively, yet the sewage from these and other fast—
growing cities on the Naugatuck River was inadequately treated by
primary and malfunctioning municipal waste treatment plants. The
Naugatuck, in effect, was a dumping ground for the region’s
domestic sewage.
On the Lower Rousatonic River, the industrial centers of
Shelton, upriver, and Milford and Stratford near the mouth of the
river, dumped their untreated municipal and industrial waste. —
including the wastes from metalworking industries — into a
stream already degraded by the wastes from the Naugatuck.
In addition to its industrial plants, the Milford area was
known for its thousands of acres of oyster beds. Due to
industrial pollution the oyster business declined after 1900 and
had continued to decline when a severe storm Lu 1951 wiped out
the cultch to which seed oysters attach themselves. After 395],
progressive pollution over the ensuing years prevented natural
recovery.
STATE AND FEDERAL CLEANUP ACTIONS
In 1967, the Connecticut Legislature enacted the Clean Water
Program. The Legislature then gave Connecticut’s Water Resources
Co iss ion broad power. to establish water quality standards for
all of Connecticut’s waters, issue cleanup orders to ãisting
dischargers to these water, and also issue permits to new
dischargers, and, finally, directed the Commission to administer
a statewide municipal sewage treatment plant construction
program.
The end—goal of the Clean Water Act was a statewide effort to
improve water quality on all state waters to eventually make them
sw1’ble and fishable. For the Naugatuck and Lower Bousatonic
Rivers, this meant upgrading their water quality to Connecticut’s
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Class B rating, a water quality classification which enables
people to fish, swia, and enjoy water contact sports in clean,
aesthetically pleasing surroundings, and also enable. fish and
wildlife to live in a pollution—free habitat.
Between 1968 and 1974. the U.S. Env1ron ental Protection
Agency (EPA) and its predecessor agency, the Federal Water
Pollution Control Administration (FWCPA) awarded $20 aillion to
construct upgraded waste trsatLent plants on the Naugatuck River
at Torrington, Thonaston, Waterbury, Naugatuck, Seyaour, Beacon
Falls, Ansonia, and Watertown, a co unity on Steele Brook, a
tributary to the Naugatuck. The State of Connecticut, in
addition, awarded $29 aillion to upgrade these plants.
All operational by the end of 1976, these facilities, with
one exception at Watertown, are activated sludge secondary
treatnent plant. with chlorination. The Watertown facility is a
trickling filter secondary treatnent plant with chlorination.
Each facility is designed to renove 85 percent of oxygen—
denanding waste, and suspended solids in aunicipal sewage.
Th
.1
I
LONG ISLAND SOUND
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—4—
Between 1966 and 1973, the EPA and the PWPCA awarded $18
million, and the State of Connecticut awarded $11.4 million, to
construct both new and upgraded waste treatment plants on the
Lover Housatonic River at Derby, Shelton, Milford and Stratford.
All operational since mid—1976, these plants are also activated
sludge secondary treatment facilities with chlorination. Like
their counterparts on the Naugatuck River, they re ve 85 percent
of oxygen—demanding wastes and suspended solids f roe municipal
sewage.
During the late 1960’s, the Water Resources Commission
ordered industry on the Naugatuck and Lover Rousatonic Rivers to
construct and install industrial pollution controls. Working
under tax credit incentives, the metalworking plants developed
systems to neutralize industrial acids, destroy cyanide wastes,
and precipitate heavy metals. The Commission also required that
metalworking industries discharging to sanitary severs provide
their own pretreatment facilities and, where possible, discharge
to surface streams rather than to municipal sewage systems —
reducing the amount of waste flows to municipal sewage treatment
plants and eliminating the possibility of plant malfunction due
to heavy metals in toxic discharges.
On October 38, 1972 Congress passed the 1972 Amendment to the
Federal Water Pollution Control Act. Section 402 of the Act
established the National Pollutant Discharge Elimination System
(NPDES). Implemented since its inception by the EPA and the
states, this system defines the requirements for permits to
discharge into the nation’s waters.
Since 1973, the State of Connecticut has issued !IPDES permits
under EPA authority.
Between 1973 and 1976, Connecticut’s former Water Resources
commission — consolidated Lu 1971 with other state agencies to
form the Department of Environmental Protection (DEP) — issued
discharge permits under the NPDES Program to 9 major municipal,
35 major industrial, and 42 minor industrial dischargers on the
Naugatuck River. Between 1974 and 1977, the DEP also issued
NPDES permits to 3 major municipal, 14 major industrial, and 11
minor industrial discharger. on the Lower Rousatonic River. By
1977, all diechargers had been issued permits. The Connecticut
DEP, however, took legal action against one discharger for
failing to comply with orders to provide adequate waste
treatment.
With this one exception, all major industrial dischargcrs on
both rivers were brought under control within the statutory tine
frame.
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—5—
RESULTS
Naugatuck River
According to Robert 1. Taylor • Director of the Connecticut
DSP’. Water Compliance and Ruardous Substances Unit, “since the
majority of modern industrial and domestic treatment systame vent
on line in the early to mid—1970’., the amount of heavy metals
and organic veatu going into the Naugatuck River decreased
dramatically.”
Since mid—1974, the DSP and the U.S. Geological Survey have
conducted an on—going chamical water quality sampling program
along the river. The results clearly show there have been marked
reductions of manganese, copper, and sine concentrations in the
Naugatuck. Before cleanup, these pollutants seriously degraded
the river’s water quality and ware tramely unfavorable to its
fish and aquatic life. The results also show markedly Improved
pH levels (a measure of acidity or alkalinity In water), and
dissolved ozygen concentrations.
Betveen mid— 1974.and 1976, the DSP, in cooperation with an
environmental consulting firm, also conducted a biological
monitoring program on the Naugatuck. “We wanted to verify,” says
DSP Senior Sanitary Engineer Charles C. Predette, “that improved
chemical characteristics in these waters were having a positive
effect in terms of the amounts and diversity of fish and aquatic
life reappearing in the river.
“We monitored the )Taugatuek three times a year,” Predate
continues, “to determine the kinds and numbers of ‘indicator
species’ in the water — organisms with varying tolerances for
pollution. Since some of these species can live only in clean or
mildly polluted waters, an Increase in their numbers indicates
improved water quality.”
Pish sampling conducted during the su er of 1975 shoved that
smalimouth bass, bluegills, bullheads, kiltif ish and eels ware
living at Beacon Pails. “While these fish were small, they were
in good condition. None of them showed signs of parasites or
disease,” Fredette says.
Similar results ware found in samples taken downstream on the
Naugatuck at Ansonia and Derby. According tO Predette, “the
results were encouraging because we had sampled these areas
before and found no fish. We also received numerous reports from
fishermen in Waterbury who took amalluouth bass and yellow perch
from the river.”
Invertebrate sampling on the Naugatuck also revealed large
numbers cf clean water indicator species such as dragonfly
larvae, dobsonfly larvae, worms, and sow bugs. The DSP used
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—6-
“natural substrate” and “artifical substrate” testing methods to
detect these creatures.
Natural substrate testing refers to material on the river
bottom, which is scooped up and analyzed for organisms.
Organism. found in the natural substrate indicate if the river
water and river bottom ar. suitable for aquatic life.
Artifical substrate testing involves packing leaves in a wire
cage, suspending the cage in the water for a number of months and
counting the organisms found among the leaves. Since the
substrate makes little contact with the river bottom, organisms
found there indicate only what the quality of the water is.
According to Fredette, far more organisms ware found in the
artificial substrate than in river bottom sediment. “The river
bottom may still be somewhat toxic from past industrial
discharges,” he points out. “While water quality has improved
dramatically, it may take several more years for the bottom
material to clean. We still find levels of zinc, lead and
manganese in the bottom mud, and zinc, chromium, and ‘cadmium n
fish. But, surprisingly, the levels in fish are not as high as
we expected.
“Since damaging discharges were discontinued,” Yredette
concludes, “we expect bottom conditions in the Naugatuck to
improve over the years.”
The Lower Rousatonic River
Today, the benefits of Improved water quality enjoyed on the
Lover Rousatonic exemplify Barry Commoner’s famous remark about
the interconnectednesa of all things in the environment.
Bluefish now swim from Long Island Sound up the Lower
Rousatonic as far up as Derby not simply because of pollution
cleanup on that river alone. Bluefish would be avoiding the
Bousatonic if it were not for massive pollution control efforts
by the cities and industries on the Nsugatuck River as wall.
By 1976, the oyster industry, wiped out by the storm in 1951
and kept out for years thereafter by progressive and pervasive
pollution, was back to its pre—1951 levels and improving.
The State of Connecticut Depart ent of Agriculture’s
Aquaculture Division is presently conducting a shellfish
management program which provides more stable, silt—free bottom
condition.. The Department of Agriculture also runs a hatchery
in Stratford where it raises oyster seed under protected
conditions.
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Since the river’s water quality has improved dramatically,
whole food chains now exist, making it possible, for instance,
with the comeback of menhaden, for bluefish to feed all the way
up the Rousatonic to Derby. This expanded habitat for bluefish
is watched by a phenomenal comeback of blue shell crabs, although
they are yet to be found in the same abundance as far north in
the Bousatonic a. bluefish.
Blue shell crabbing as a sports attraction draws great
interest near the mouth of the river, a fact appreciated by
sportsmen who had seen this species disappear in the past. And
local citi!ens can now fish, picnic by, and boat along a pleasant
and far cleaner river.
KP IWGUE
Today, with the exception of one discharger, all of the
Naugatuck’s heaviest polluting industries have some kind of
pollution control. AU of the industries along the Lover
Rousatonic also have controls.
tu 1967, the water quality of the Naugatuck and Lover
Rousatonic Rivers was rated at Class D or below, fit only for
navigation.
In 1977, the Naugatuck from Torrimgton to Thomaston was rated
at a awismable and fishable Class B • From Torrington to the
point where the Naugatuck meet. the Lower Eousatouic at Derby,
the river wa, rated at Class C, a quality level capable of
supporting recreational boating and a fish and wildlife habitat.
The Lover Rousatonic bad improved to full Class B status, but
municipal sever overflow. during rainfall at Derby and Shelton
prevent the river from achieving a consistent Class B rating.
The Connecticut DEP has ordered thus cosmnmities to study
solutions to thus problems.
When sill th. entire Naugatuck River be sviwaiable and
fishable?
The Connecticut DSP is presently conducting stud is. to
dstsrmine ths degree of advanced waste trut ent that the cities
on the Naugatuck will have to provide to remove additional
organic m.t.s in their municipal waste discharge.. Assuming
that all of the trsat ent plants on the Naugatuck can be upgraded
soon to provide .dvanc.d trutm ’t, the DSP antic ipatu that the
Naugatuck River ‘will achieve full Class B water quality status by
1984.
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—8—
(Information for this story s contributed by Messrs. Richard 3.
Barlow, Charles C. Prdetts, and Brian D. Ccci, Connecticut DEl,
and by Mr. Steven Barkowit., Valley Regional Planning Agency,
Derby, Connecticut. Their valued assistance is peatly
apprsciatsd).
Other success stories in print :
Buffalo River, New York
Detroit River, Michigan
Xodiak Rarbor, Alaska
Esceabia Bay, honda
Willanette River, Oregon
Monongahela River, r7est Virginia
and Pennsylvania
Pearl River near Boga]uu, Louisiana
Ogden Bay, Great Salt Lake, Utah
Grove and Center Creek., Missouri
Sope Creek 1 Cobb County, Georgia
Dillon Reservoir, Colorado
Yellowstone National Park, Wyoning
Lake Miunetonka, Minnesota
Backensack River, New Jersey
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UNITED STATES WIflOU 1E!JTAL PROTECTION AGE ;cY
RECION I
DATE i
SUBJECTs Consent order to General Electric Company (UGE)
under sections 3007, 3013 and 7003 of RCRA,
42 U.S.C. &927, 6933 and 6973, concerning
PCfla in the flousatonic River in Massachusetts
and Connecticut
FROM s Leslie Carothers
Acting Regional Administrator
Region I
$ Anne 4. Gorsuch
Admini aerator
?ffROVCHs Richard Wilson
Acting Assistant Administrator
for Enforcement
ISSUt s
Should the Ad.’ tinistrator approve and sign the onclosed consent order
requiring GE to study and develop re edia1 plans for PCD’s disposed
of by the ca pany in the liousatonic River and neighboring sites?
DISCUSSIO’7 :
1. Syno ,sis
This is an administrative order which GE hae agreed to enter as a
consent order. It involves an interstate Pollution rroble , the
contanination of the Flous3tonic River in western 3ass ichusetts aM
connecticut by PCBs disposed of by CC since the 19308 at its
Pittsfield assachusatts, factory. This order La the product of
extensive discussIons ar on the technical and legal staff of (!,
EPA and the Massachusetts Dcpartmet t of nvironrtental Quality
Enginecring ( ! Z’). D • baa izsued a consent order which iiposes
the sane reouircnents az TP ’s, except that EPA’S reauires additional
wor) in the state of connecticut. The Conn. cticut Dapartnent of
Envirori ental Protection (“ EP ) sought EPA’s involvement in this
case, and reviewed and cos riented on a draft of the order. The order
requires studies of PC!!e in the sedi onts, waters and fish of the
rivers, a study of alternative courses of reLledial action at a PC2
hot spot identified in previous stulies, and reporting on past
PC dis osa1 practices. The order would be issuo 1 un or provisions
added to RC1tA in 1900. Authority to use those provisions has not
been dc1o atec1 to the Regions. Staff attorneys fron the Of ficc of
I1a:ardour aste knforcenent have p rticipatec1 in the developrent of
this order and are familiar with it3 contents.
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2. Description of Source
GE operates a factory at 100 Woodlawn Avenue, Pittsfield,
MassachuSetts, 01201, ectploying utore than three thousand people.
Its operations include the r.anufacture of power transfori ers, in
which it used polychlorinatcd biphenyls (PCbs) froia the early
1930s until 1977. CC also panufactured electric capacitors in
Pittsficld irot the 1930 ’s until the 1950s, when it rioved the
capacitor operation to tlc’w York.
During the four decades of PCfl use in Pittsfield, PC?—contaminatcd
wastes were disposed of at various sites in Pittsfield, and large
quantitieo were discharged into the Ilousatonic Itiver and two bodies
of water which empty into the Housatonic, Silver I ke and Unka et
Brook. The discharge of PCBs was first subject to lir its under
GE’s Naticnal Pollutant Discharge l lir tnation Systen (NPDES) Permit
(No. i A0C03b91) in 1975; GE co plted with these limits. G began
voluntarily phasing out PCEI use, so that it wao entirely eliminated
by 1977. }(t sidual trace amounts are still allowed by the perit it;
effluent sar. p1es t en by E?J’a jfl Iloveriber, L9 U found YCas in two
of the tan outtalis, but the quantities, 1.6 and 0.4 parts per
billion (p b), were insignificant. T iis order is thus not based on
per it violations, but on £i’A’s authoritj to address substantid
hazards to health or the environn cnt arising fror past disposal of
hazardous waste, unaer sections 3007, 3013 and 7003 of RCIA.
In addition to PC s, GE b s generated other hazardous wastes at
Pittsticld. Ow measure Lox dispo a1 of PCDs and other hazardous
wastes ,,as the ‘Waste Stabilization Da in,’ which discharged into
Un a et I3rook. GE recently discovered that PCfls and other hazardous
wastes have accw ulated in the sediments of the lagoon and the brook,
and entered the groundwater. This order requires that GE report on
its disposal c both PC3s and other wastes at the Basin, and si i1ar
locations if any exist. te order also rcquirea that GE report on
its re edia1 easuros and on its plans for future uioriitoring.
3. EPA’s Authority Under RCPA
Section 3007 of BC A, as a ended in 1980, gives EPA the authority,
‘for tha pur o e of enforcing the provthion9 of this title,” i.e.,
all the provisions of RCRA, includincj sections 3013 and 7003, to
request iron “any person who generates,... disposes of, or
otherwise handlus or has handiecl hazardous wastes,” to ‘furnish
information relating to such wastes....’
Section 3013(a) of RcflA, added in 1980, provides:
If the Adi iniatrator determines, upon receipt of any
inforaation, that
(l) the presence of any hazardous waste at a
facility or site at which hazardous wat tc is, or baa
been, stored, treated, or dibposed oi , or
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(2) the release of any such waste frog such facility
or site
s*ay present a substantial hazard to human health or the
environ ent, he n y issue an order requiring the owner
or operator of such facility or site to conduct such
ronitoring, testing, analysis, and reporting with
respect to such facility or site as the Adi inistrator
dce s reasonable to ascertain the nature and extent of
such hazard.
Section 7003(a) of RCM, as awendcd in 1980, provides, in its
relevant parts, that;
upon receipt of evidence that the handling, storage,
treathent, transportation or disposal ot any solid
waste or hazardous waste s ay present an thminent end
substantial enoancjerr-ent to health or the envir.nsent...
(t)he Adi inistrator i:.ay.... after notice to the atfectcd
State. take.. action..., including... issuing such
orders as r.ay be necessary to protect puDlic health and
the environient.
These sections require only evidence of a potential danger to
health or the environr. ent, not proof of actual ham, or a violation
of law. he danger may be only environmental; proof of a threat to
buu an health is not required.
Neither section requires that the waste involved be listed a a
hazardous waste by EPA under section 3001 of RCRA. Section 3013
requIres that the wastes be hazardous wastes as defined in RCRA,
and section 7003 deals with both solid and hazardous waste, a
defined in RCE A. RCflA’s definitions, secticns 1004(5) and (27),
are set forth on pages two and three of the order. Thus, these
sections can be applied to a case involving PCDs, even though
PCDs are not listed as a hazardous waste under RCRA. PCD—
cont inated waste meets the definition of hazardous waste, in
section 1004C5) of JtCRA, i.e., it is a waste
which because of its... chamact ristics may... pose a
substantial present or potcnti . 1 hazard to human health
or the environment when iz roper1y... dis oscd of....
The PC s in this case were disposed of prior to April 18, 1978, the
effective datu of the PCB disposiil regulations prwwlgutcd under
the ozjc Substances control Act, 15 U.S.C. 26U1 Ct seq . (TSC \).
PCils are listed as a 9iazardous Con3tituent’ in Appendix VIII to
40 C.F.R. Part 261. The presence OL one u these constituents
in a waste is a criterion for listing the waste as hazardous under
Part 2b1.
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This case is thus not governed by TSC . I4oreover, section 9(b) of
TSCA provides for the use oz other laws by kFA to adcires3 risks to
health or the cnvironr ent associated with toxic substances. Thu 0
TSCA does not preclude the appLication of sections 3013 and 7003 of
RCRA to this case.
Authority to issue administrative orders under these .1980 aicndr ents
to RCt.A has not yet been delegated to the Regional Ad@intstrators.
This order rnust therefore be signed by the Adi inistrator.
4. t atura of the Environmental end Health _ ) azards
PCB conta’ ination of the Housatonic has been extensively docuL ented.
Warnings against eating the river’s fish have been in effect since
1975. The river is popular for fishing and recreation, so there
can be no doubt that the warnings and subsequent curtailrnent of
fish stoc :ing have bad an econo! ic impact on the region. Actuel
health effects on hui ans are harder to deteriaine. Connecticut is
studying PCbs in people who eat liou atonic fish, but the data is
not yet available. Furttwr details of the environt ental impact
are set forth in the order. -
One question not addressed in the order is the difference in toxicity
among the various I’CD rnixtures. Inforraation is not yet available
on the conposition of the PCE3s in the river, so this question must
be addressed when ore data on the river has been obtained.
A principal focus of this order is an irnpoundwent of the river
known as Woods Pond, which is in liassachusetts behind the first da
downatroan of G ’s Pittsfield facilities. Studies have indicated
that a large portion of GE’s PCLs have accui u1ated in the sedii icnts
in Woods Pcnd. ‘this ‘hot spot’ i a be a continuing source of PC S
in both the waters and food chains of the river, and t ey account
for the continuing high levels of PCbs In fish uownstrcam. It
also pose a threat of catastrophic release in the event of a x: a or
storr., or a failure of the darn. Conccrn with these dangers is high
among people downstream.
A second Locus of this order is jroundwater contamination in
locations near the Lousatonic in Pittsfield. GE has voluntarily
addressed some of these pro lei s, so that the principal need is for
further i onitoring and reporting. tfowcver, Pittsfield residents
have requested both the state and EPA tO coflduct independent
samplin9 and review of GE’s work to assure ther. that any hazards
which f0A exist will be identified, and that proper reLlcdial
E.easurcs either have been, or will be, taken. It is also necessary
to assure, as much as possible, that grounuvater contamination Of
the Housatonic is not t ing place.
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5. Re u1atory ifistory
cc Pittsfield has generally complied with all environmental laws
and per ts. They have, however, been issued two orders, one in
1972 by the state, requiring development of treatment at several
diUcrent outfalls, and the Other in 1973 by EVA, for failure to
cet permit limits for the discharge of phenoLs into Unkamet brook.
GE has been involved in proceedings in other places involving PC3s,
particularly in ZJev York State, where CC entered a consent
agreement with the state in 1976, concerning clean—up of PCBs in
the } udson River.
6. State Coordination
EPA has workud closely with Nassachusetts DIQ1 in developing this
order. DEQE izas issued a parallel order, the only difference
being that UEQE does not require study in Connecticut.
The provision of the order which calls for a report on past
hazardous waste disposal practices was dovelo ed by L)EQE. GE has
used nurerous øisposal sites in the Pittsfield area, and has also
cause] groundw iter contnr.ination by accidental Icakaqe arid spillage
in ao ’e locations. G has voluntarily undcrt cn to abate some oE
this pollution, but the state wishes to be sure that all known
sites re bcin addressed, and wishes to gather as ch intor ation
from GE as possible.
The Connecticut DEP which has already carried out extensive studies
of the Liousatcnic, revieveci and cotu ented on the penultimate draft
of this order, and several of their coi ents were incorporated into
the final draft. Further coordination with DEP is anticipated in
respect to study of the river in Connecticut, and the interstate
transport of PCEs.
EPA Region I is planning a study of possible PCB sources other than
GE, which will require coordination with both states. There is
also an ongoing State—EPA i greeinent on the interstate Transport of
Pollutants (SEA*), which provides for quarterly public meetings on
the Housatonic and other interstste rivers.
7. CE’s Willingness and Readiness to Comply
GE has indicated that it has already budgeted for, and begun work
On, the studies called for in this order. The order is the product
of lengthy discussions among technical and legal staff of EPA, L)CVz
and GE. By entering the order as a consent order, GE has certified
its willingness to comply.
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8. Citizen Suits
An irportant aspect of this case is the existence of at least two
citizun lawsuits seekincj injunctive relief against GE. The
plaintiffs are all Connecticut residents. One group petitioned EPA
in October, l9 0 to take action under section 7003 of RCRA. EPA
responded to this petition in Decc?nber, 1980, pointing out that
action under section 7003 is discretionary, so that EPA cannot be
sueJ for choosing not to take action. The suits against CC are
still awaiting trial; the plaintiffs iray be willing to have thefl
continued pending the conpietion of the studies required by this
order.
Citizens and public officials fror Pittsfield, Massachusetts, have
also souvht EPA’S involver4ent with these probleris.
It is rccoi cnøed that this adniriistrative oroer tjissued in the
forr agreed to by G . Ti’e order will require G to perform an
extensive study of PCD hazarcs in the I ousatonic and related
waters, and to study alternative coursc oL rcL edial action,
includinj no action, at woods Pond. The studies wiLl enable PA
to provide a tully infori ed response to intense and widespread
public concern.
Aithougn a parallel state order is being issued, federal action is
needed, particularly in light of the substantial interstate aspect
of this case. EPA involver.ent has repeatedly been sought by
citizens, state officials and Conçrcssr.en fro i Connecticut. Close
stata/fedural cooperation is planned for the review of GE’S study
proposals, and for analysis of duplicate sar.ples in the oversiqht
of the studies. CPA’s technical resources arc needed for this
work. In addition, any concerned citizens have sought EPA’s review
of Cc’s voluntary studies, in order to assure their credibility;
this assurance will undoubtedly be sought in the future.
Covipliance by GE is assured. This order will initiate a pro jrai
for an effective restoration of the tiousatonic as a valuable
econo ’ic resource, a ccntral asset to one of the principal
recr.at onal racJ3.ons acctssiole to New york City and Southern cw
Englan J. If successful, the progran will be a I ajor cooperative
acco.tplishr ent for CPA, the states, and private industry.
uestions concernincj this order ay be addressed to Lawrence 1.
Goldr.an, the Acting Director of the Entorces cnt Division of ‘egion
I, at (617) 223—3470, or Charles coring, an attorney in Region I’s
Lnforce,nent Division, at (617) 223—5470, or Jim Okun, an-engineer
in egion l’s Inforce; ent Division, at (617) 223—2007.
1
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UN ITED STATEC ENVI RCNMENTATJ PROT ECT ION AGENCY
Lester A. Sutton, P,E.
Regional Administrator
DATE: August 21, 1981
BJECT: PCBs from GE’s Pittsfield Facility — Chronology of
Government Actions
FROM: Lawrence M. Goldman, Acting Director ,
Enforcement Division
TO:
The following is a chronology of events relating to GE’s facility in
Pittsfield, Massachusetts. The chronology covers four different
issues: PCBs i the Housatonic River; PCBs in the ground in Pitts-
field, particularly in th “Lakewoo’V’ neighborho3J; PCBs and other
ia zardous wa L s in Urikamst Bcook; and ?CB incineration. Atta ed
are three maps. The first shows the entire Housatonic River, and
indicates the location of Woods Pond, the principal PCB “hotspot.”
The second and third attachments are part of a map of Pittsfield,
showing GE’s facilities and outfalls into the Housatonic, Silver
T ake and Unkar et Brook. The sec on map also shows the “Lakewood”
‘ 3ighborhoOd. Also attack - is a ore—page summary of tasks required
of GE under the 1981 consent order.
CHRONOLOGY
1932 (approxir tely)
1970—1977
December 16, 1974
GE begins use an discharge of PCBs in
Pi L bf1 .&d.
Water, fish and sediment studies of PCBs
reveal continuing high levels in the
Housatonic River. After extensive sampling
in 1976, EPA proposes modification of the
NPDES permit to address the PCB potential
hazard.
NPDES permit issued limiting PCB discharger.
Massachusetts and Connecticut issue health
warnings against eating Housatonic fish, and
curtail trout fishing.
March, 1977
September 15, 1977
1978
GE terminates use of PCI3s ir manufacturing
in anticipation of TSCA prohibition.
First of five citizen law suits against GE
filed. Others filed 11/77, 12/77, 6/78 and
7/79.
C t’ begins studies of PCBs in theflousatonic
with $200,000 apptopriation from legislature.
These studies are still in progress.
1977
.
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January 23, 1980 GE notifies EPA of ongoing study of ground-
water contamination by PCBs and other
hazardous wastl3s.
February, 1980 GE reports to EPA and DEQE on PCBs and other
hazardous wastes in Waste Stabilization
Basin and Unkamet Brook.
July 1, 1980 CT releases preliminary results of study of
Housatonic sediments by Dr. Charles Frink,
identifying Woods Pond as principal hotspot.
August 19, 1980 EPA responds to GE’s incineration requests,
authorizing incineration of liquids under
500 ppm PCBs, but denying GE’s request to
burn PCBs in concentrations greater than 500
ppm until a trial burn has been sucessfully
completed.
October 20, 1980 EPA receives petition for action against GE
under RCRA Section 7003 from Connecticut
citizens group, who have already sued GE.
November, 1980 Massachusetts State Representative Scelsi
requests EPA assistance in reviewing GE’s
study of PCB plume near “Lakewood” neighbor-
hood in Pittsfield.
December 2, 1980 Connecticut DEP presents results of trout
studies to quarterly SEA meeting, indicatin•
continued high levels of PCBs. cr citizens
group, the “PCB Watchdog Committee,” issues
statement calling for EPA leadership in
remedying the Housatonic’s problems.
December 4, 1980 Letter from Congressman Toby Moffett of
Connecticut to EPA, Region I, repeats Watch-
dog Committee’s call for EPA action; also
calls for meeting between Commissioners Pac
(CT) and Cortese (MA) and EPA RA.
December, 1980 to EPA, DEQE and GE agree to negotiate an
April, 1981 administrative order to initiate further
studies of PCB contamination in the River
and to develop remedial action alternatives
for certain known or suspected hotspots.
ay 26, 1981 GE signs federal and state consent orders.
DEQE order formally issued. It is identical
to EPA’S order, except that it does not
address the Connecticut portion of the river.
EPA order transmitted to IIQ.
•June, 198]. Draft FIT repo :t on La c ?ood releazed. GE
objects to certuin aspects of the report.
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-.3 ..
Ju 3b, 198]. Deputy Administrator Hernandez,. EPA, signs EPA
order for Administrator Gorsuch.
July, 198]. S&A performs air samples for PCBs in Lakewood
basements.
July 16, 1981 Signed .copy of order transmitted to GE.
Letter from Acting RA, EPA, designates July 16,
1981 as effective date. GE immediately sub-
mits Housatonic River Study Proposal for
review by EPA.
August, 1981 Region I is awaiting comments on GE’s proposal
from CT DEP. DEQE has approved proposal.
EPA LQ is still reviewing. Region I, GE and
its consultant, Stewart Labs, and DEOE are
planning to meet in Lexington in September.
Results of the Lakewood air sampling show no
significant levels of PCBs; a report on the
Lakewood air sampling is being prepared.
HQ has put the Versar contract* on hold. We
are still awaiting word on GE’S trial burn
at its incinerator.
attachments
kVersar contract — EPA funded investigation to locate other possible
sources of PCB discharges to the Ilousatonic River.
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Attachment 4
Tasks Required of General Electric Company (Pittsfield)
, l times are from the issuance date of the order (July 16, 1981).
Within thirty (30) days:
IsThe Housatonic River Study Proposal”, which was submitted on
July 17, 1981, called for in III, b. of, the order.
The purpose of this study is to monitor, test, analyze, and
report on the contamination of the Ifousatonic River, Unkamet
Brook, and Silver Lake. The order calls for completion of the
¶tudy ‘it tn one year of issuance of the order, a deadli. which
may now ha e to be amended due to the nearness to the end of warm
weather.
2. Within ninety (90) days:
SU IIII L portion of report on the “Report on Past Hazardous Waste
Disposal Practices and Remedial Actions”
This summary is to inform EPA of the remedial actions and environ-
mental studies GE has taken to date, arid its plans for future
monitoring at the Waste Stabilization Basin and Unkamet Brook.
-. Within one hunared and eighty (180) days:
Report on Past Hazardous Waste Disposal Practices and Remedial
Act i on a”
For this report, GE is to search all of its relevent files and
interview appropriate plant employees to determine all possible
past hazardous waste disposal sites. This information, ,ith the
iniormation on ongoing rei edia1 action i easures, make up this
report.
4. Within sixty (60) days of the completion of the liousatonic River
Study:
“Woods Pond 5tudy Proposal”
At this time, evidence has been submitted to EPA which indicates
a large accumulation of PCBs in the impoundment known as Woods
Pond. As this is in all likelihood the most contaminated area,
a plan for complete study, and possible remedial action is
required. The order calls for completion of the study within one
hundred and eighty (180) days of approval of the proposal by EPA.
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