HUDSON RIVER PCBs REASSESSMENT RI/FS
PHASE 3 FEASIBILITY STUDY
SCOPE OF WORK
SEPTEMBER 1998
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Prepared for:
U.S. Environmental Protection Agency
Region II
and
U.S. Army Corps of Engineers
Kansas City District
Prepared by:
TAMS Consultants, Inc.
New York, NY
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
R^GiON 2
290 BROADWAY
NEW YORK. NY 1 0007-1366
SEP 2 3 1998
To All Interested Parties:
The U.S. Environmental Protection Agency (EPA) is pleased to release the Phase 3 Feasibility
Study Scope of Work for the Hudson River PCBs Superfund site Reassessment. This document
describes the approach to be taken by EPA to evaluate remedial alternatives for the PCB-
contaminated sediments in Upper Hudson River. The Feasibility Study will be conducted in
accordance with applicable regulations and EPA guidance.
The Feasibility Study (the Phase 3 Report) is scheduled to be released to the public in December
2000. EPA will concurrently issue a Proposed Plan for the site, which will identify and describe
the Agency's preferred alternative. After a public comment period, EPA will then select a
remedy for the site, which will be documented in the Record of Decision.
EPA will accept comments on the Feasibility Study Scope of Work until Monday, November 2,
1998. Comments should be marked with the name of the report and should include the report
section and page number for each comment. Comments should be sent to:
Douglas Tomchuk
USEPA - Region 2
290 Broadway - 20th Floor
New York, NY 10007-1866
Attn: FS SOW Comments
Similar to the release of previous Reassessment reports, EPA will make presentations on the
Feasibility Study Scope of Work, as well as the Ecological Risk Assessment Scope of Work, at a
Joint Liaison Group meeting on the day of release. EPA will follow-up with an availability
session to answer the public's questions regarding these documents. The availability session will
be held on Tuesday, October 20, 1998 at the Marriott Hotel, 189 Wolf Road, Albany, New York
from 2:30 to 4:30 p.m. and from 6:30 to 8:30 p.m.
If you need additional information regarding this Scope of Work, or with respect to the
Reassessment in general, please contact Ann Rychlenski, the Community Relations Coordinator
for this site, at (212) 637-3672.
Sincerely yours,
William McCabe, Deputy Director
Emergency and Remedial Response Division
Internet Address (URL) http://www.epa.gov
Recycled/RaeyciabI* Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer)
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HUDSON RIVER PCBs REASSESSMENT RI/FS
PHASE 3 FEASIBILITY STUDY
SCOPE OF WORK
SEPTEMBER 1998
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Prepared for:
U.S. Environmental Protection Agency
Region II
and
U.S. Army Corps of Engineers
Kansas City District
Prepared by:
TAMS Consultants, Inc.
New York, NY
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Phase 3 - Feasibility Study
Scope of Work
Hudson River PCBs Reassessment Rl/FS
Table of Contents
1. INTRODUCTION 1
1.1 Site History 3
1.2 Objective and Scope 5
1.3 Schedule 7
2. DEVELOPMENT OF REMEDIAL ACTION OBJECTIVES AND GENERAL
RESPONSE ACTIONS 9
2.1 Applicable or Relevant and Appropriate Requirements 9
2.2 Remedial Action Objectives 10
2.3 General Response Actions 16
3. IDENTIFICATION AND SCREENING OF APPLICABLE TECHNOLOGIES
AND PROCESS OPTIONS 19
3.1 Technology and Process Option Identification and Screening 20
3.2 Evaluation of Technologies and Process Options 21
4. DEVELOPMENT. SCREENING AND DETAILED ANALYSIS OF REMEDIAL
ALTERNATIVES 25
4.1 "No-Action" Alternative 26
4.2 Effectiveness Evaluation 27
4.3 Implementability Evaluation 28
4.4 Cost Evaluation 28
4.5 Detailed Analysis of Remedial Alternatives 29
5. FEASIBILITY STUDY REASSESSMENT REPORT 31
REFERENCES 33
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Phase 3 - Feasibility Study
Scope of Work
Hudson River PCBs Reassessment RI/FS
Table of Contents
List of Tables
(tables provided at end of report)
Table Number Title
1 Potential Chemical-Specific ARARs and Criteria. Advisories and
Guidance
2 Potential Location-Specific ARARs and Criteria. Advisories and
Guidance
3 Potential Action-Specific ARARs
4 Initial Identification of General Response Actions and Remedial
Technologies
List of Figures
(figures provided at end of report)
Figure Number Title.
1 Hudson River PCBs Reassessment Feasibility Study Modeling
AnaKsis Flowchart
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1. Introduction
This document describes the work to be performed in Phase 3 of the Hudson River PCBs
Reassessment Remedial Investigation and Feasibility Study (RTFS). For the purposes of the Hudson
River Reassessment, the RI/FS process has been separated into three phases as follows:
1. Interim Characterization and Evaluation, which included a compilation of
historical data and information related to the Superfund site, a preliminary evaluation
of human health and ecological risks, and a determination of data gaps:
2. Further Site Characterization and Analysis, including extensive sediment
(chemistry and geophysical), surface water, and biota sampling as necessitated by the
Phase 1 findings, as well as development and calibration of PCB fate and transport
models, and preparation of baseline human health and ecological risk assessments:
and
3. Feasibility Study, including an evaluation of "No Action" as well as an appropriate
range of remedial alternatives which will reduce risk to humans and biota from
exposure to PCB contamination, utilizing data compiled during Phases 1 and 2 and
models and risk assessments developed in Phase 2. and other data and information
as necessary.
The Hudson River PCBs Superfund site extends from Hudson Falls. New York (River Mile
[RM] 197) to the Batten, in New York City (RM 0). USEPA's previous Feasibility Study (USEPA.
1984a). the interim "No-Action" decision for contaminated river sediments in the 1984 Record of
Decision (ROD: USEPA. 1984b). and rationale for this Reassessment are described in the Phase 1
Report for this Reassessment (TAMS/Gradient. 1991). The scope of potential remedial activities for
this Reassessment is limited to the PCB-contaminated sediments in the Upper Hudson River between
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Hudson Falls and Federal Dam at Troy (RM 153.9). The Phase 2 investigation
(TAMS/Cadmus/Gradient. 1997) confirmed that generally higher levels of PCB contamination are
found in the Upper Hudson (above RM 153.9) and thus this area should be the primary focus of the
Feasibility Study. However, impacts to both the Upper Hudson River and Lower Hudson River will
be addressed in the risk assessments.
To date, the USEPA has issued five major reports summarizing the analyses performed for
the Hudson River PCBs Reassessment. In August 1991. USEPA issued a Phase 1 Report, entitled
Interim Characterization and Evaluation (TAMS/Gradient, 1991), which described the results of
Phase 1 studies. The Phase 1 Report contains a compendium of background material, discussion of
findings, and preliminary assessment of risks. The Phase 2 work began in December 1991 (upon
approval of the earlier Phase 2A Sampling Plan) and is still ongoing. Four reports have been released
from this phase of the investigation, specifically:
Phase 2 Report. Volume 2A: Database Report - October 1995;
Phase 2 Report. Volume 2B: Preliminary Model Calibration Report - October 1996:
Phase 2 Report. Volume 2C: Data Evaluation and Interpretation Report (DEIR) -
February 1997: and
Phase 2 Report. Volume 2C-A: Low Resolution Sediment Coring Report - July 1998.
The Responsiveness Summary for these four volumes of the Phase 2 Report (Volumes 2 A to 2C-A)
will be released later this year.
This scope of work outlines the technical approach and major tasks for the Feasibility Study
to be issued in December 2000.
The complex and controversial nature of PCB contamination in the Hudson will be an
important consideration in the preparation of the FS. From both a technical and community
perspective, there are many unique concerns and challenges associated with the selection of a
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remedial action for the river. Because of the complex nature of sediment PCB contamination and its
relationship to water and biota contamination, computer models will be employed to assist in the
selection of remedial objectives as well as to assess the likely success of any remedial action in
attaining these goals.
1.1 Site History
The Hudson River PCBs Superfund site encompasses the Hudson River from Hudson Falls
to the Battery in New York Harbor, a stretch of nearly 200 river miles (322 km). During an
approximately 30-year period ending in 1977. two General Electric (GE) facilities, one in Fort
Edward. NY and the other in Hudson Falls. NY. used PCBs in the manufacture of electrical
capacitors. Estimates of the total quantity of PCBs discharged from the two plants to the river from
the 1940s to 1977 range from 209.000 to 1.330.000 pounds (95.000 to 603.000 kg)
(TAMS/Gradient. 1991). In 1977. manufacture and sale of PCBs w ithin the US w as stopped under
provisions of the Toxic Substances Control Act (TSCA).
Many of the PCBs discharged to the river adhered to sediments and accumulated downstream
with the sediments as they settled in the impounded pool behind the former Fort Edward Dam (RM
195). as well as in other impoundments farther downstream. Because of its deteriorating condition,
the dam was removed in 1973. During subsequent spring floods. PCB-contaminated sediments were
scoured and transported downstream. A substantial portion of these sediments were stored in
relatively quiescent areas of the river. These areas, which were surveyed by New York State
Department of Environmental Conservation (NYSDEC) in 1976 to 1978 and 1984. have been
described as PCB hot spots. Exposed sediments from the former pool behind the dam. called the
"remnant deposits." have been capped by GE under a consent decree w ith USEPA.
Although commercial uses of PCBs ceased in 1977. loading of PCBs derived from the GE
plants to the Hudson River continued, due primarily to erosion of contaminated remnant deposits,
discharges of PCBs via bedrock fractures from the GE Hudson Falls plant, and erosion from
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contaminated deposits above the water line near the GE Fort Edward plant outfall. Capping of the
remnant deposits (in the area of RM 195 to RM 196) was completed in 1991. In September 1991.
high PCB concentrations were again detected in Hudson River water. GE attributed the higher levels
to the collapse of a wooden gate structure within the abandoned Allen Mill located adjacent to the
GE Hudson Falls capacitor plant (RM -197) (O'Brien and Gere. 1993). As reported by GE. the gate
had kept water from flowing through a tunnel cut into bedrock below the mill, which contained oil-
phase PCBs that migrated there via subsurface bedrock fractures. During 1993 to 1995. extensive
PCB contamination was detected in water conduits within the mill and approximately 45 tons of
PCB-bearing oils and sediments were eventually removed (O'Brien and Gere. 1995). In 1994. GE
documented the presence of PCB dense non-aqueous phase liquid (DNAPL) seeps in a dewatered
portion of the river bottom at Bakers Falls adjacent to the Hudson Falls plant site. GE instituted a
number of mitigation efforts that have resulted in a decline, but not total cessation, of these seeps
(O'Brien and Gere. 1995). A more in-depth discussion of external PCB sources, including the GE
facilities, the remnant deposits, and other sources in both the Upper and Lower Hudson River, is
contained in the Phase 2 Data Evaluation and Interpretation Report (TAMS/Cadmus/Gradient.
1997).
In 1984. USEPA issued a Record of Decision (ROD) for the site (USEPA. 1984b). The ROD
selected: 1) an interim "No-Action" decision concerning river sediments; 2) in-place capping,
containment, and monitoring of remnant deposit sediments; and 3) a treatability study (at the
Waterford Water Works) to evaluate the effectiveness of removing PCBs from the Hudson River for
domestic water supply.
In December 1989. USEPA Region II began a reassessment of the "No-Action" decision for
the Hudson River sediments based on the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA) five-year reevaluation requirement for remedies that leave
contamination on site: the reopener in the 1984 ROD: and the request from NYSDEC to conduct the
Reassessment. The ongoing reassessment consists of three phases: Phase 1 - Interim
Characterization and Evaluation: Phase 2 - Further Site Characterization and Analysis; and Phase
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3 - Feasibility Study. This document represents the scope of work for the Phase 3 Feasibility Study
that will be developed for the Reassessment.
The 1984 ROD does not address PCB DNAPL seeps near the GE Hudson Falls plant, which
were unknown at the time. Also, the outfall area at the GE Fort Edward plant site is likely a source
of PCBs to the river (TAMS'Cadmus'Gradient. 1997). Remedial activities at the GE Hudson Falls
and Fort Edward sites are being performed under Orders on Consent between NYSDEC and GE. The
changing loading from the GE sites upstream of the Thompson Island (TI) Pool will be considered
in evaluation of remediation for the Hudson River.
1.2 Objective and Scope
The overall objective of the Phase 3 Feasibility Study is to develop and evaluate an
appropriate range of remedial alternatives which will reduce risk to humans and biota from exposure
to PCB contamination. This effort is the continuation of preliminary FS efforts (e.g..
TAMS/Gradient. 1991 and TAMS. 1997) which were initiated in Phase 1. Based on the results of
the Phase 3 work. USEPA will select a remedy (or "No Action") which meets the requirements of
CERCLA while taking into account the recommendations and concerns of New York State and the
local communities affected.
Preliminary remedial action objectives will be refined and developed. For protection of
human health (i.e.. consumption of contaminated Fish or ingestion of water), it is anticipated that the
remedial action objectives will be defined primarily for the media of exposure (e.g.. fish and water)
and not in terms of sediment levels unless direct sediment exposure is involved. Although, in the
Hudson River, the sediments are not typically the medium of PCB exposure for assessing human
health risks, nonetheless they comprise one of the main sources of PCBs to the exposure media and
thus will be the focus of the FS. For protection of biota (i.e.. benthic invertebrates, fish, birds, and
mammals), direct exposure to sediment will be considered in the ecological risk assessment.
However, the link between sediment PCB levels and the exposure media is complex. As a result, as
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part of the Phase 2 investigation, computer-based, geochemical and ecological model components
are being developed to simulate the sediment-water-biota interactions. USEPA will also utilize a
model of the Lower Hudson River developed by Drs. Robert Thomann and Kevin Farley for the
Hudson River Foundation. As part of the FS. the USEPA Reassessment and Thomana'Fariey
models w ill be used to examine the impact of possible remedial actions in the Upper Hudson River
on PCB levels in fish and water in both the Upper Hudson River and Mid-Hudson River (in this
case, the Mid-Hudson is defined as the freshw ater portion of the Lower Hudson River from Federal
Dam at Troy to Poughkeepsie. NY). In this manner, the model responses will be used to suggest both
the degree and extent of cleanup (i.e., concentration threshold and spatial coverage) as well as the
likely timeframe for measurable improvements attributable to the remedial actions. This approach
is unique to a relatively few complex Superfund sites, since action levels are typically established
in a direct fashion from human health risk assessment calculations, ecological risk assessment
calculations or applicable or relevant and appropriate requirements (ARARs). Ultimately, all four
approaches (modeling, human health and ecological risk assessments, and ARARs) will be
considered in establishing the remedial action objectives for the sediments.
Based on the results of the then-established remedial action objectives and the results of the
baseline human health and ecological risk assessments, the initial screening of remedial alternatives
will be performed according to the procedures recommended in "Guidance for Conducting Remedial
Investigations and Feasibility Studies under CERCLA" (USEPA. 1989). as well as the National
Contingency Plan (NCP). The subtasks to be completed during the initial screening process include:
Development of remedial response objectives and general response actions;
Identification and screening of remedial technologies and specific process options for
each technology; and
Development and screening of remedial alternatives, which can comprise one or
more remedial technologies.
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Upon completion of the initial screening, the remaining alternatives will be subjected to
detailed analysis. The results of the entire FS process will be described in the Reassessment FS
Report.
It has been USEPA's continuing goal since this Reassessment commenced to solicit
information and provide feedback to the public through a Community Interaction Program (CIP).
CIP participants and committees have provided written and verbal comments throughout the project.
These comments are useful and greatly appreciated. Comments on this document will be reviewed
and considered in the development of the Phase 3 FS.
1.3 Schedule
The FS report is scheduled to be released in December 2000.
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2.
Development of Remedial Action Objectives and General
Response Actions
As discussed above, the remedial action objectives will be developed based on the results of
the Phase 2 investigation. These objectives will be constructed in light of data collected for the
Reassessment as well as data from other sources (e.g.. GE. NYSDEC. National Oceanic and
Atmospheric Administration [NOAA], and US Fish and Wildlife Service [USFWS]). Prior to the
development of these objectives, significant site concerns and contaminant pathways identified in
the previous phases will be examined. Considering these concerns and pathways, the remedial action
objectives that would eliminate or minimize substantial risks to public health and the environment
will be developed further. Included in this step is the development of potential remedial action
objectives via the use of the geochemical and ecological model results to suggest both the degree and
extent of sediment remediation necessary to reduce exposures to acceptable levels. ARARs will be
refined by considering site-specific conditions. Based on the remedial action objectives, general
response actions will be delineated to address each of the site concern areas. These response actions
will form the foundation for the screening of remedial technologies. General response actions
considered will include the "No-Action" alternative as a baseline against which the other alternatives
can be compared.
2.1 Applicable or Relevant and Appropriate Requirements
Section C.3 of the Phase 1 Report (TAMS/Gradient. 1991) initially addressed applicable or
relevant and appropriate requirements (ARARs) in some detail. Tables 1. 2 and 3 herein represent
updated but not final lists of potential chemical-specific, location-specific and action-specific
ARARs. respectively. As part of the Phase 3 effort, the ARARs will be reviewed and modified as
appropriate in light of Phase 2 analyses and other appropriate data. The revised ARARs w ill then
be used during Phase 3 screening and detailed analysis tasks.
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As originally indicated in USEP.Vs Responsiveness Summary for the Phase 1 Report
(TAMS'Gradient. 1992 ). NYSDEC will provide USEPA with a complete list of State ARARs and
To Be Considered Requirements (TBCs) for USEPA's use in the Phase 3 FS. An initial list of
ARARs was provided by NYSDEC in 1994. This list will be updated by NYSDEC in Phase 3.
Tables 1. 2 and 3 include the ARARs provided by NYSDEC in 1994 as well as other ARARs.
Although extensive, the tables contain only potential ARARs. A final evaluation and selection of
the ARARs will be done in Phase 3.
2.2 Remedial Action Objectives
Remedial action objectives serve as guidelines in the development of alternatives for site
remediation. Remedial action objectives should specify the contaminants and media of concern,
exposure routes and potential receptors, and an acceptable concentration limit or range for each
contaminant for the various media, exposure routes and receptors. In constructing these objectives
for the Hudson, it will be necessary to establish both acceptable concentrations as well as areas
requiring remediation. Accessibility of contamination to humans, the water column and biota will
all figure in the selection of areas for remediation.
The results of the preliminary risk assessments completed in Phase 1 indicate that the
contaminants of concern are PCBs and that the primary exposure route is consumption of aquatic
life. The receptors are the consumers of aquatic life: human receptors and ecological receptors (fish-
eating birds and mammals). As extensively discussed in the Data Evaluation and Interpretation
Report (TAMS/Cadmus/Gradient. 1997). the sediments are g major, if not the major, source of PCBs
to the water column in the Upper Hudson. Since the exposure of aquatic life to PCBs must take place
either through sediment-based or w ater-based exposure routes, the primary medium of concern is
Upper Hudson River sediments. Establishing remedial action objectives on the basis of these
exposure routes will require analysis and modeling. Additionally, direct human and ecological
exposure to PCB-contaminated sediments and water may also pose unacceptable risks and provide
an additional basis to establish remedial action objectives. Ecological receptors will include
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piscivorous birds and mammals as identified above as well as fish, benthic invertebrates, and
insecti\orous birds. In addition to risk-based remedial action goals. PCB concentrations in I'pper
Hudson River water and sediment may exceed limits specified in State and Federal ARARs or other
criteria, advisories or guidance to be considered. The refinement of ARARs described in Section 2.1
above will provide input to the development of remedial action objectives.
Target contaminant concentration limits or ranges may be developed for various media and
receptors as part of the process of developing remedial action objectives. Concentration limits may
be based on ARARs or the results of the human or ecological risk assessments. The concentration
limits would be set to reduce incremental human cancer risk to between 10"4 and 10'6 or to reduce
the non-carcinogenic Hazard Index (HI) to below 1.0. Ecological contaminant concentration limits
would be set at levels demonstrated to be protective of ecological receptors. Target concentration
limits will also be developed using the geochemical and ecological model components to examine
the relationship between various sediment concentrations and attainment of acceptable PCB levels
in fish and other biota (e.g.. FDA limits).
In addition to setting target contaminant concentration ranges or limits, it will also be
necessary to specify areas of sediment to be addressed. PCB concentration in sediment alone is
unlikely to be a sufficient criterion, since PCB transfer to the water column and biota would be
expected to vary with other environmental factors, such as sediment type, proximity to biologically-
important areas and depth of contamination. Thus different areas might be assigned different target
levels or be remediated in different w ays. Selection of areas for remediation w ill be done based on
the criteria developed during Phase 2 and finalized in Phase 3. including ARARs and the results of
the human or ecological risk assessments. Areas for remediation will also be developed in
conjunction with the modeling efforts. The geochemical and ecological model components will be
used to determine the spatial extent of cleanup and the recovery of fish and biota body burdens.
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Development of Remedial Action Objectives from the Hudson River Models
Potential remedial action objectives will he developed from the Reassessment models of PCB
geochemical fate and transport and ecological impact as well as from the risk assessments and
ARARs. As part of the Phase 2 investigation, these models will be calibrated and subsequently run
to estimate future river conditions assuming no remedial activities are implemented to control
sediment-related PCBs. This model run will define the "No-Action" scenario which will be
compared with subsequent model runs simulating various remedial options. In addition, the models
will be used to predict PCB fate and transport for a 100-year flood event in the Upper Hudson. As
part of the Phase 3 effort, these models will also be run assuming various remedial actions have
taken place, resulting in changes in the sediment PCB inventory {e.g., dredging) or exposure
pathway (e.g.. capping). One scenario that might be considered would involve the removal or
isolation (e.g., capping) of all sediments with PCB concentrations greater than 50 mg/kg (ppm).
Model outputs from each run would be examined to see if the scenario would impact body burdens
of PCBs in fish and other biota. If such changes did occur, the timing and scale of the change relative
to the "No-Action" scenario would be evaluated. In this manner, the scale of change in sediment
conditions required to produce a substantive change in fish and biota body burdens could be
estimated.
Utilizing this approach, both the scale and timing of the recovery of fish body burdens could
be examined relative to the degree of remediation implemented. It is anticipated that at least 20
model runs will be required. Likely remedial scenarios to be tested in this manner include:
Removal or isolation of all sediment in the Upper Hudson (Rogers Island to Federal
Dam) with average PCB concentrations greater than 50 mg/kg;
Removal or isolation of all sediment in the Upper Hudson with average PCB
concentrations greater than 1 mg/kg:
Removal or isolation of all sediment in the Upper Hudson with average PCB
concentrations greater than the risk assessment-derived acceptable concentration;
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Removal or isolation of all contaminated sediment in the NYSDEC hot spots.
Removal or isolation of all sediment with average inventories greater than 10 g nv
(mass of PCBs per unit area of sediments):
Removal or isolation of all fine-grained sediment based on the side-scan sonar results
(which extend to Lock 5) and removal of hot spot areas below Lock 5:
Bank-to-bank dredging of the Thompson Island Pool (TIP) sediments:
Bank-to-bank dredging of the TIP sediments and removal of NYSDEC hot spots
below the TI Dam;
Removal of contaminated sediments w ith average PCB concentrations greater than
10 mg/kg w ithin 50 ft of shore and removal or isolation of sediments greater than 50
mg/kg for deeper locations: and
Removal of all contaminated sediment associated with the proposed NYSDEC
dredge locations as documented in Malcolm Pimie. 1992.
In each instance the magnitude of fish and biota body burden recover, would be examined.
Similarly, the time needed to achieve the recovery or the time to achieve some preset threshold (e.g..
the FDA limit or an ecological threshold) would be examined relative to the "No-Action" scenario.
Because the various remedial scenarios will have different impacts at various locations, the model
may also be used to provide information on the extent and rate of recovery at upstream and
downstream stations (e.g.. TI Pool v.*. Stillwater). In this manner, a range of possible remedial action
objectives and their likely impact on the recovery of fish and biota body burdens in the Upper
Hudson and Mid-Hudson will be developed. Results from these model runs will also be used to
assess the degree and timing of the recovery of water column PCB concentrations to ARAR-
specified or risk assessment-derived levels.
It should be noted here that although the Mid-Hudson will be examined using models to
assess PCB risks under the "No-Action" scenario and select remedial action scenarios. Lower
Hudson model components will not be used in the determination of remedial action objectives for
the Upper Hudson. This exclusion is based on the premise that Lower Hudson biota will be less
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affected by remedial efforts in the Upper Hudson relative to resident Upper Hudson biota. Proximity
to the more concentrated sediments and any potential remedial actions in the Upper Hudson suggest
that Upper Hudson biota should be most responsive to any remedial action. Therefore, the Upper
Hudson models should be used as a basis for selecting remedial action objectives. However, the
Lower Hudson models will be used to assess the impacts of select Upper Hudson remedial scenarios
on Mid-Hudson water column and biota concentrations. PCB loadings from the Upper Hudson will
be specified as input to the Lower Hudson model.
It is anticipated that the modeling analysis to develop remedial action objectives will be done
in an iterative manner wherein model results from previously defined scenarios will aid in selecting
conditions for subsequent model runs. Figure 1 represents the general modeling approach to be used
for both the Phase 2 and Phase 3 efforts. Highlighted in the figure is the model iteration loop
expected to be used in the development of model-based remedial action objectives. It is expected that
only one of the ecological models w ill be used in the iterative process. However, once the analysis
is near completion using one of the ecological models, the results will be confirmed to the extent
possible with the remaining two models. The diagram show s the probabilistic model in the iteration
loop but the actual ecological model selected for this purpose will be determined at the completion
of the baseline modeling effort.
This approach has the potential to provide a great deal of insight regarding possible remedial
actions and their likely outcomes. How ever, the outcome of the modeling effort can be no better than
the data set on which it is based. Therefore. TAMS and its subcontractors are currently developing
and calibrating the various model components utilizing available data from a wide range of sources,
including the Phase 2 sampling efforts. NOAA. NYSDEC. USGS and GE. Even so. due to the scale
and complexity of PCB contamination in the Hudson, there remain a number of less well-understood
issues or parameters which may add a degree of uncertainty to model output. As a result, the model
output cannot be used as the sole basis for the selection of remedial action objectives. Rather, it must
be considered in the context of other remedial goals and USEPA guidance in the selection of
remedial action objectives.
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Lastly, it is important to note here that the inclusion of any specific remedial approach within
the range of possibilities presented (e.g.. bank-to-bank dredging of the Thompson Island Pool) at this
point in the FS does not indicate a predilection to that particular approach. Rather, a wide range of
scenarios need to be considered in order to correctly assess the effectiveness of various remedial
approaches relative to the others. The main point of the modeling is to provide a basis on which to
evaluate various remedial action scenarios in view of attaining acceptable PCB body burdens in fish
within an acceptable timeframe. In performing this analysis. TAMS will incorporate guidance to be
provided by USEPA as to the desired level and timing of the recover) of fish body burdens.
Final Selection of the Remedial Action Objectives
While the final list of remedial action objectives will be developed by the USEPA. it is
expected that these objectives will ultimately be designed to reduce risk to human and ecological
receptors, to achieve water quality criteria, and satisfy other ARARs. In this regard, the objectives
w ill be designed to attain one or more of the follow ing goals:
reduce PCB concentrations in Hudson River fish below the FDA-acceptable level of
2 ppm which is based on human health considerations or to other acceptable levels
based on site-specific risk assessments or ARARs by reducing or mitigating PCB
sediment concentrations. This will require a determination of (a) the desired level
in fish: (b) the timeframe in which the fish are to reach the desired level: and (c) the
location at which this objective is to be achieved (e.g.. Troy vs. Thompson Island
Pool):
reduce human health risk associated with exposure to near-shore contamination to
an acceptable level (to be determined by USEPA. expected to be in the range of lO'4
to 10'6 incremental carcinogenic risk) by reducing or mitigating PCB sediment
concentrations. The specific concentration goal will be based on the Phase 2 human
health risk assessment to be released in August 1999:
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reduce ecological risk associated with the exposure of ecological receptors to PCB-
contaminated water and sediment, based on input from the ecological risk assessment
to be released in August 1999:
reduce PCB water column concentrations to the NYS promulgated surface water
standards (based on the recent NYSDEC update. TOGS 1.1.1. June 1998 and 6
NYCRR 703.5) of lxlO"6 ug/L (0.001 nanogram [ng]/L) for protection of human
consumption of fish or 1.2xlO"1 ug/L (0.12 ng/L) for protection of wildlife by
reducing or mitigating PCB sediment concentrations: and
reduce the inventor.' of sediment PCBs available for interaction with the river,
perhaps by removal or isolation of previously-defined hot spots refined by more
recent studies (e.g.. removal or isolation of areas where the highest concentrations
of PCBs are at or near the surface and are thus not being buried by "clean material").
To facilitate the start of Phase 3 FS work, pending the completion of Phase 2. it will be
assumed that the target maximum PCB concentration in sediment remaining in contact with river
water or potential receptors to be achieved by remediation is in the range of 1 to 50 mg/kg.
2.3 General Response Actions
A summary of the general response actions for remediation of the Upper Hudson River
sediments include the following:
1. "No Action":
2. Monitored natural attenuation:
3. Containment:
4. In situ treatment:
16
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5. Complete or partial removal with on-site dewatering and subsequent on-site or off-
site disposal: and
6. Complete or partial removal with on-site or off-site treatment and disposal.
The distinction between "No Action" and "monitored natural attenuation" (or natural
recovery) is important. "No Action" means that no active remedial measures will be taken at the
site, because the site poses no current or potential threat to human health or the environment. No
institutional controls (e.g.. fishing bans) are implemented as part of a "No-Action" alternative.
Monitoring is the only activity that may be considered as part of the "No-Action" alternative.
Similarly, in a "monitored natural attenuation" alternative, no active remedial measure would
be implemented. In contrast to "No Action", however, the "monitored natural attenuation"
alternative is expected to achieve site-specific remedial objectives within a timeframe that is
reasonable compared to that offered by other more active methods. Natural attenuation could occur
by in situ processes such as biodegradation. dispersion, dilution, sorption, volatilization, and
chemical or biological stabilization, transformation, or destruction of PCBs. Monitoring of the river
would be an important aspect of a natural attenuation alternative. It is also possible that institutional
controls would be required until remedial objectives are met.
When relying on natural attenuation processes for site remediation. USEPA prefers those
processes that degrade contaminants. It is most appropriate at sites that have a low potential for
contaminant dispersion. Monitored natural attenuation may be used in conjunction with, or as a
follow-up to. active remediation measures.
For general response actions 5 and 6 identified above, "on-site" refers to a corridor including
the Upper River and extending two miles from either bank. In addition to these individual response
actions, combinations of these actions w ill also be considered due to the varied nature of sediment
PCB contamination and its large spatial extent. For example, containment might be combined with
in situ treatment in order to achieve a remedial action objective for a hot spot area. Similarly, in situ
17
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treatment might be combined with complete removal in a setting where PCB contamination extended
from near-shore (complete removal) to deeper sediments (in situ treatment). Removal rather than
containment (capping) or in situ treatment will be considered the preferred action for contaminated
sediments within the limits of the navigation channel, if necessary.
It is believed that the full range of general response actions for the site has been identified,
and that it will not be necessary to conduct further work on developing general response actions in
Phase 3.
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3. Identification and Screening of Applicable Technologies
and Process Options
Based on the remedial action objectives and each identified general response action, potential
treatment technologies and their associated containment or treatment and disposal requirements will
be identified. A prescreening of these potential treatment technologies for suitability as part of
remedial alternatives will be conducted. Where several process options exist for a particular
technology, the process option for which most data exist and whose capabilities/constraints most
closely match site conditions will be selected for further detailed evaluation. The final selection of
a process option will occur during development of a Record of Decision.
Technologies that could prove extremely difficult to implement, might not achieve the
remedial objective in a reasonable time, or might not be applicable or feasible based on the site-
specific conditions will be eliminated from further consideration. A two-step screening process w ill
be used to select technologies and process options for further consideration.
As is discussed below, an initial tw o-step screening of applicable technologies and process
options has already been undertaken. A list of technologies considered is provided in Table 4. This
screening, completed in 1994. will be updated in Phase 3 to reflect currently available technologies
as well as the better defined constraints on available sites for landfilling and treatment facilities.
It is expected that this portion of the Phase 3 effort can proceed concurrently with the
development of remedial action objectives. However, finalization of this step will require a final
selection of remedial action objectives.
19
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3.1 Technology and Process Option Identification and Screening
During Phase 1. several established and innovative technologies within several response
action categories were identified. These and other technologies identified since that time will be
examined for their implementability. Those technologies that are infeasible to implement will be
eliminated from further evaluation.
The criterion for elimination of a particular technology or process option during Phase 3 will
be technical feasibility. Technologies or process options will be determined to be technically
infeasible based on study area-specific factors. Conditions, such as a sediment matrix being
incompatible with a technology or process, restricted access of the process equipment to the possible
remediation areas, and other such factors will be grounds to eliminate technically infeasible
processes. Results of treatability studies presented in the literature or provided by technology
vendors may be considered in the screening process, as appropriate. Technologies or processes that
are removed from further consideration will be documented in the Phase 3 Report.
While this step prov ides some level of technology screening, in many cases the wide range
of river conditions serves to simply segregate various technologies based on the anticipated location
or use. For example, standard dredging techniques which can be employed in deeper portions of the
river may be unsuitable for near-shore sediment removal. Alternatively, installation of sheet piling
and sediment removal by standard soil excavation equipment may be suitable for the near-shore and
shallow sediment environments. The latter technique may have subsequent limitations due to the
shallow depth to bedrock in some locations, preventing a cost-effective installation of sheet piling.
Thus it is unlikely that any single set of technologies will be suitable for all remediation areas. As
part of this process, a suite of technology sets which can be employed dependent on the conditions
of the remediation area will be developed.
An initial screening of technologies with respect to technical feasibility has been conducted
as part of the initial FS work. This screening will be updated and finalized as part of the Phase 3
20
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effort. In the initial review, several technologies were screened out based on the scale of the potential
cleanup effort. For example, solvent extraction of PCBs in sediments was eliminated as an in situ
treatment option based on the large scale of the remediation required and the difficulties involved
in controlling solvent migration in difficult-to-constrain sediments. Similarly, centrifuge techniques
were eliminated as a potential sediment pretreatment/dewatering process based on the anticipated
large volumes of sediment to be treated. Several techniques for ex situ treatment, including specific
solvent extraction processes, were eliminated for reasons such as materials handling difficulties.
3.2 Evaluation of Technologies and Process Options
Those technologies and process options carried forward for the second screening step will
be evaluated based on three criteria:
effectiveness:
implementability: and
relative cost.
This screening step w ill evaluate each process option within the same technology type to
determine which is most effective. The process option determined to be most effective will be
carried forward in the screening evaluation for further development. Typically, process effectiveness
depends on such factors as:
1. The ability to handle the range of sediment volumes that could require remediation.
Prior estimates of sediment remediation volumes for the hot spots alone were over
one million cubic yards (Malcolm Pirnie. 1992). The actual volume to be remediated
w ill of course be dependent on the selected remedial action objectives and will be
determined in Phase 3 after the final selection of objectives is made by USEPA.
21
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2. The ability to meet a range of remediation goals. It is expected that sediment cleanup
levels will be established on the basis of current sediment inventories, proximity to
shore and human receptors, and potential for re-release. Thus several different
concentration objectives are possible.
3. Potential impacts to human health or the environment during construction and
implementation. In this regard, the ability to control the release of dredged sediment
to the river via spill and leakage must be considered. Also, volatilization of PCBs
from treatment streams during devvatering or other ex situ processes may need to be
considered.
4. Whether the process or technology is proven and reliable for site-specific
contaminants and conditions. For example, any ex situ process must not be adversely
affected by the presence of heavy metal contamination also found in some Hudson
River sediments.
Because of the range of conditions anticipated in the Hudson River, several technologies for
each response action may be carried forward when it is apparent that no single technology can handle
the anticipated range of conditions. For example, see the discussion in Section 3.1 concerning the
use of dredging vs. dry excavation techniques in river areas of varying depths.
Implementability is evaluated based on both technical and administrative factors. Technical
implementability screening would include site-specific and process-specific considerations, such as
volume of material to be processed, compatibility or effectiveness with other than target
contaminants or conditions, site access limitations or weather-related concerns, among others.
Administrative considerations include any federal or state permit requirements and municipal
constraints, availability of treatment equipment and facilities to the project within the required
timeframe, and the availability of technology vendors or suppliers.
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Falling into the administrative category is the amount of space available for siting a
pretreatment facility. Due to the extensive use of the neighboring areas for agriculture, housing and
recreation, the number of sites with the large open areas necessary for this purpose are limited u7.
Landfill Treatment Facility Siting Survey [TAMS. 1997]). It is anticipated that portions of the
combined remnant deposit areas present a potential location for such a facility. This limitation
presents a substantive constraint on those technologies which require large areas of land in order to
operate. Based on the initial second level screening conducted by TAMS in 1994. technologies such
as land farming and composting, which require very large areas of land in relation to the volume of
material treated, were screened out.
Similarly, recent municipal and county resolutions opposing landfilling of PCB dredge spoils
in agricultural areas would make the administrative process of selecting a local landfill site difficult.
Thus, off-site landfilling will also be considered in the FS technology screening. As part of Phase
3. the secondary technology screening performed in 1994 w ill be updated and finalized to reflect
currently available technologies as well as the potential limitations to landfill site selection.
Relative capital and operation and maintenance (O&M) costs, rather than detailed estimates,
are used for this evaluation. An evaluation is made of high, moderate, and low cost process options
at this stage.
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4. Development, Screening and Detailed Analysis of
Remedial Alternatives
The FS process will continue in Phase 3 with the development of remedial alternatives from
the technologies and process options that survive the technology screening. The development of
alternatives requires combining appropriate remedial technologies from the screening described
above in a manner that will satisfy the remedial action objectives (see Section 2.2). It is anticipated
that several processes will be needed within each remedial alternative in order to cover the range of
conditions anticipated in the Upper Hudson River. Remedial alternatives will be developed in each
of the following categories.
Alternatives for treatment that would eliminate, or minimize to the extent feasible,
the need for long-term management (including monitoring) of Upper Hudson River
sediments:
Alternatives which use treatment as the primary component to address the principal
threats related to Hudson River sediments with a requirement for long-term
monitoring;
Alternatives which use removal without treatment as the primary component to
address the principal threats related to Hudson River sediments;
Alternatives that rely on containment with little or no treatment, but are protective
of human health and the environment by preventing potential exposure to
contaminants or by reducing their mobility;
A "monitored natural attenuation" alternative; and
A "No-Action" alternative.
The potential remedial alternatives developed in the categories above will be screened. The
objective of this effort is to reduce tHe number of technologies and alternatives for further analysis
while preserving a range of options. This screening w ill be accomplished by evaluating alternatives
25
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on the basis of effectiveness, implementability and cost as specified in the USEPA guidance
document (USEPA. 1989). These screening criteria are described below in Sections 4.2 through 4.4.
Information developed forthq Landfill Treatment Facility Siting Survey (TAMS. 1997) will be used
in the development and screening process.
It is possible, pending the results of the ongoing risk assessments, that remedial alternatives
may be developed separately for different areas of the river. For example, alternatives may be
developed to reduce the risk associated with near-shore sediments which pose a dermal contact risk
for waders. Alternatives for remediation of these sediments may not be the same as alternatives
designed to achieve the other remedial action goals for the project. Remedial alternatives which
utilize several technologies may be constructed depending upon the conditions encountered.
4.1 "No-Action" Alternative
A "No-Action" alternative will be formulated and assessed to determine its human health and
ecological risk levels. This alternative is identical to the scenario developed for the baseline
modeling report. The "No-Action" alternative will be carried through the entire FS process
(alternatives screening and detailed analysis) to provide a basis for comparison with other more
aggressive remedial alternatives.
The "No-Action" alternative will include no containment, removal or treatment of river
sediment, and could include the following components:
long-term PCB monitoring in sediment, water or biota; and
continuation of current institutional controls, such as fishing bans.
Monitoring and institutional controls can be included in the "No-Action" alternative because
they are currently in place and are not "remedial" in nature. The "No-Action" alternative means that
no additional remedial actions will be taken.
26
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4.2
Effectiveness Evaluation
Using the quantitative methodologies developed in Phase 2. human health and ecological
risks associated with each remedial alternative, including the "No-Action" alternative, will be
evaluated. Both short-term risks, associated with the implementation of a remedy and the time
period required for stabilization thereafter, and risks over the long term, after transient remediation
conditions are stabilized, will be evaluated. For evaluation of long-term risks, scenarios that meet
model-based remedial action objectives can utilize the model output to assess the long-term changes
in risk to humans and the environment. Short-term risks associated with the period of remediation
are much more difficult to quantify due to the lack of information on the nature of PCB releases
during this time. Although both resuspension and air-borne releases may take place during removal
and treatment, the ultimate fate of these specific materials will not be well-known. As a result, any
risks posed by these materials will be handled qualitatively only.
In light of this potential concern, qualitative considerations of the potential for PCB release
during the remedial process will be included in this evaluation. Thus, a process which minimizes the
storage of PCB-bearing sediments during the removal and treatment process would be preferred over
a process which must have a large volume of material on hand to operate effectively. Similarly, a
removal process which is highly effective at preventing resuspension would be preferable over a
process wherein a portion of the sediments removed was regularly lost.
It is anticipated that the same exposure pathways identified in Phase 1. such as ingestion of
contaminated fish, will be of concern for the remedial alternative evaluation. The final resolution of
pathways w ill be resolved in the completion of the human health and ecological risk assessments.
Effectiveness will be judged in the context of reducing risk via these pathways, both quantitatively
and qualitatively.
21
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4.3 Implementability Evaluation
The implementability evaluation will be used to measure both the technical and
administrative feasibility of constructing, operating and maintaining a remedial action alternative.
In addition, the availability of the technologies involved in a remedial alternative will be considered.
Innovative technologies will be considered throughout the screening process if there is a
reasonable belief that they offer potential for comparable treatment performance or implementability.
fewer or lesser adverse impacts than other available approaches, or lower costs for similar levels of
performance than demonstrated technologies.
Administrative implementability will include a consideration of the land requirements for
the various remedial alternatives, among other issues. Specifically, for example, the amenability of
the alternative to the anticipated use of the remnant deposit areas will be considered here. Whether
locations other than the remnant deposits are available for a treatment or dewatering facility will also
be considered. Similarly, the requirement to create a permanent facility such as a landfill will also
be considered. No alternative will be excluded based solely on its need for a landfill: however, in
light of local concern and opposition to such facilities, greater land requirements inherently imply
greater implementation difficulties.
4.4 Cost Evaluation
Cost evaluation will include estimates of capital costs, annual operation and maintenance
(O&M) costs, and present worth analysis. These conceptual cost estimates are order-of-magnitude
estimates, and will be prepared based on preliminary conceptual engineering for major construction
components, and unit costs of capital investment and general annual O&M costs available from
USEPA and US Army Corps of Engineers documents, from the technical literature and from TAMS"
in-house files. TAMS also will utilize relevant information found in USEPA and other government
and private on-line databases for current cost information.
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4.5 Detailed Analysis of Remedial Alternatives
The remedial alternatives that pass the screening will be subject to a detailed analysis,
including presentation of a conceptual design and layout. The detailed analysis will consist of
technical, environmental and cost evaluation, as well as an analysis of other factors, as appropriate.
The detailed analysis will follow the process specified in the NCP and the "Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA" (USEPA. 1989).
Given the anticipated rigorous and unique path to this point in the FS process, it is unclear
how many remedial alternatives will require detailed analysis. It is currently estimated that five such
alternatives will be evaluated, but this number is highly dependent on the remedial action objectives
selected. It is expected that each of the remedial alternatives will have at least two and probably more
technologies which enable the alternative to address the various river conditions.
The NCP identifies a set of nine evaluation criteria that are to be applied in the evaluation
of each remedial alternative. These nine criteria are grouped into three categories to develop the
rationale for a remedy selection, including "threshold" factors, "primary balancing" factors, and
"modifying" considerations. These are:
"Threshold" Factors:
Overall protection of human health and the environment: and
Compliance w ith ARARs.
"Primary Balancing" Factors:
Long-term effectiveness and permanence:
Reduction of toxicity, mobility, or volume through treatment:
Short-term effectiveness:
Implementability: and
Cost.
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"Modifying" Considerations:
State acceptance: and
Community acceptance.
In this context, long-term effectiveness and permanence refers to the ability to maintain
protection of human health and the environment after response objectives have been met as well as
the adequacy and reliability of controls (if any) that are used to manage treatment residuals and
untreated wastes (USEPA. 1989). In particular, long-term effectiveness will consider the degree to
which the contamination is effectively isolated from the river over a long period of time. For
example, removal of PCB-bearing sediment followed by treatment would provide a greater degree
of long-term effectiveness for river sediments relative to an in-place capping scenario since the
stability of the cap over the long term, particularly in light of major floods, would be less assured.
Short-term effectiveness refers to the ability to maintain protection of human health and the
environment during the construction and implementation phase until remedial response objectives
are met (e.g.. a cleanup target has been met) (USEPA. 1989). This evaluation criterion includes a
consideration of the time required to achieve protection. For example, implementation of removal
of PCB-bearing sediment to off-site landfills relative to in-place capping would likely result in a
greater human health risk due to potential exposure during material handling.
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5. Feasibility Study Reassessment Report
The FS Reassessment Report will be prepared to summarize the Phase 3 activities and to
present the results and associated conclusions. The FS report will be prepared and presented in the
format specified in "Guidance for Conducting Remedial Investigations and Feasibility Studies Under
CERCLA" (USEPA. 1989). This report will represent the culmination of the entire Reassessment
and provide the basis for the final steps in the RI/FS process: the proposed plan and record of
decision.
In the report, the feasibility of technologies and process options for site remediation will be
identified for each general response action, and the results of the remedial technology screening w ill
be described. Remedial alternatives developed by combining the technologies identified in the
previous screening process, and the results of the initial screening of remedial alternatives with
respect to effectiveness, implementability and cost will be described.
A detailed description of the cost and non-cost features of each remedial action alternative
passing the screening w ill be presented. A detailed analysis of each remedial alternative w ith respect
to each of the evaluation criteria w ill be presented, along with a conceptual design and layout, as
appropriate. A comparison of these alternatives w ill also be presented.
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References
Limno-Tech/Menzie-Cura & Associates Cadmus. 1996. "Phase 2 Further Site Characterization and
.Analysis - Model Calibration Report (Volume 2B)." Review Copv. Prepared for USEPA Region
II. NY, NY.
Malcolm Pimie. Inc. 1992. Hudson River PCB Project. Proposed Dredeing Locations. Prepared for
NYSDEC. Albany. NY.
NYSDEC. 1998. Ambient Water Quality Standards and Guidance Values and Groundwater Effluent
Limitations. Division of Water Technical and Operational Guidance Series (TOGS) 1.1.1. Reissue
date: June 1998.
O'Brien & Gere Engineers. Inc. 1988. "Hazardous Waste Site Remediation, the Engineer's
Perspective." Van Nostrand Reinhold Company. NY. NY.
O'Brien & Gere Engineers. Inc. 1993. "Bakers Falls Operable Unit 3. Interim Remedial Measure."
Prepared for General Electric Company.
O'Brien & Gere Engineers. Inc. 1995. "Fort Edward Dam PCB Remnant Containment 1994 Post-
Construction Monitoring Program." Prepared for General Electric Company.
TAMS. 1992. "Final Phase 2 Work Plan and Sampling Plan. Hudson River PCBs Reassessment
RI/FS." Prepared for USEPA Region II. NY. NY.
TAMS. 1997. "Landfill-Treatment Facility Siting Survey. Hudson River PCBs Reassessment
RI/FS." Prepared for USEPA Region II and the US Army Corps of Engineers. Kansas City District.
TAMS/Cadmus/Gradient. 1997. "Phase 2 Report - Further Site Characterization and Analysis:
Volume 2C - Data Evaluation and Interpretation Report." Review Copy. Prepared for USEPA
Region II. NY. NY.
TAMS/Gradient. 1990. "Scope of Work. Hudson River PCBs Reassessment RJ 'FS " Prepared for
USEPA Region II. NY. NY.
TAMS/Gradient. 1991. "Phase 1 Report - Review Copy. Interim Characterization and Evaluation.
Hudson River PCBs Reassessment RI/FS." Prepared for USEPA Region II. NY. NY.
TAMS/Gradient. 1992. "Responsiveness Summary for the Phase 1 Report. Hudson River PCBs
Reassessment RI/FS." Prepared for USEPA Region II. NY. NY.
33
TAMS
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TAMS/Gradient. 1995. "Phase 2 Further Site Characterization and Analysis - Database Report
(Volume 2A)." Prepared for USEPA Region II. NY. NY.
USEPA. 1984a. "Feasibility Study. Hudson River PCB Site. New York.*" USEPA Region II. NY.
NY.
USEPA. 1984b. "Record of Decision. Hudson River PCB Site." USEPA. Region II. NY. NY.
USEPA. 1989. "Guidance for Conducting Remedial Investigations and Feasibility Studies under
CERCLA." EPA 540/G-89/004. Office of Emergency and Remedial Response. Washington. DC.
USEPA. 1989. "Risk Assessment Guidance for Superfund, Volume 1. Human Health Evaluation
Manual. Part A" EPA/540/1-89/002. Office of Emergency and Remedial Response. Washington.
DC.
USEPA. 1990. "Guidance on Remedial Actions for Superfund Sites with PCB Contamination."
EPA/540/G-90/007. Office of Emergency and Remedial Response. Washington. DC.
USEPA. 1991. "Handbook: Remediation of Contaminated Sediments." EPA'625/6-91/028. Office
of Research and Development. Washington. DC.
34
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TABLES
-------
TABLE 1
POTENTIAL CHEMICAL SPECIFIC ARAKS AND CRITERIA, ADVISORIES AND GUIDANCE
MEDIUM/
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CONSIDERATION IN THE RI/ES
BIOTA
federal Regulatory
Requirements
federal lood. Drug and
Cosmetic Act
Relevant and
Appropriate
Hits sets forth 1 DA limit of 2 ppni lor PCU
concentrations in commercial fish and shellfish
To be determined
SURFACE WATER
New York Slate
Standards
6 NYCRR 703,
NYSDI C KKiS 111
(June IW8)
Applicable
1 stablislies water quality standards for various
classes of surface water Standards for I'CUs are
0.001 ng'I, for protection of human health (fish
consumption) and 0.12 ng/L for protection of
wildlife.
Potential ARAR for establishing It'll
cleanup ciilcria for Hudson River water
federal Criteria,
Advisories, and
(iuidanee
federal Water Pollution
Control Act and Ambient
Water Quality Criteria
(AWQC)
To Ik- Considered
f ederal AWQC are ecological and health-based
criteria developed for various pollutants,
including total I'CUs and individual Aroelors
freshwater chronic (ecological) criterion for
total PCBs is 0 014 ug/L.
To be determined
Sale Drinking
Water Ac! and
Regulations
42 DSC 3OOf el seq; 40
CIK 141
Relevant and
Appropriate.
Maximum Contaminant l evel (MCI.) for PCBs
in finished drinking water supplied to consumers
of public water supply systems is 0.5 ug/L; goal
(MCl.Ci) is zero.
Relevant and appropriate since Hudson
River water is used as a drinking water
supply source for several communities.
I'oxic I'olluianl
I:IHucnl Standards
Clean Water Act; Pollutants
listed in 40C1 R40I; It'll
criterion in 40 CI'K 129.
Applicable.
1 he ambient water quality criterion for navigable
waters is established at 0.001 ug/|. total PCBs
(40CIR 191 105(a)(4)). It'll manufacturers
prohibited from discharging PC Bs.
Applicable; Hudson River is a navigable
water. Applicability of manufacturing
discharge prohibition to be determined
NY SPIJI S limits
6 NYCKR Parts 700-757,
NYSDI:C IXKiS 1,3 4
Applicable
Discharges of PCBs should be non detected,
based on practical quant nation limit of 0.3 ug/l.
It lis
Applicable to activities (e g . remediation)
involving discharges of water to the
Hudson River
Source IfciM-d mi 1;11>Ic (1-1 ul the IIhinc I Report, upd.ilcd 5/05/«#5 ;md WVJ*
-------
I'm KIN I IAL (. Ilhivm Al,-M'f.l IMI AKAK> AINIJ t.KI I KKIA, AIIVIMJKI».?> AINII l.HIDAINC K
MEDIUM/
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOI'SIS
CONSIDERATION IN THE RI/KS
AIR
federal Regulatory
Requirements
CAA - National Ambient
Air Quality Standards
(NAAQS)40CfR 50
Relevant and
Appropriate
These standards were primarily developed for
particulates and conventional air pollutants No
specific standard for I'CHs.
Standards for particulate matter will be
used when assessing excavation and
emission controls for sediment treatments
New York Stiilc
C lean Air Act (6 NYCRK
25b and 257)
Applicable
establishes an air quality classification system
and air quality standards No specific standard
loi I'CHs
Standards lor emissions from remedial
activities.
federal Criteria,
Advisories. and
(iuidancc
American Council of
Ciovemmental and
Industrial 1 lygienists
Threshold Limit Values
(II V)
1 o Ik' Considered
1 licse slandaids were issued as consensus
standards for controlling air quality in workplace
cnvironmcnts.
TI.Vs could be used for assessing site
inhalation risks for soil removal
operations
New York State
Guidance
Air (iuide-1 (NYSDfC
Division of Air Resources;
Dralt, 1991)
To Me Considered
f.stahlislics Short-term Guideline Concentrations
and Annual Guideline Concentrations (S(iCs and
ACiCs) lor I'CHs (0.1 ug/in' and 0.00045 ug/m')
Applicable to emissions ol I'CHs from the
Hudson River (e.g.. volatilization);
potentially applicable to various remedial
actions.
SKDIMKN 1"
New York Stale
technical (iuidance lor
Screening Contaminated
Sediment. November 199};
April 1996 update
1 o He Considered
(iuidance document used by the Division of
Marine Resources, Division olT ish and Wildlife,
for evaluating contaminant levels in sediment.
Calculated value based on fraction organic
carbon and oclanol-watcr partition coefficient of
the contaminant.
Criteria lor determining water and
sediment levels for protection of human
health (bioaccumulation). benlhic aquatic
life (acute and chronic toxicity), and
wildlife (bioaccumulation). Values lor
I'CHs var> by several orders of magnitudc
for the four levels ol protection
National ()eeame
and Atmospheric
Administration
Potential for Biological
1 fleets of Sediment-Soibed
Contaminants - l ech
Memorandum NOS OMA
52, March 1990
To He Considered
(iuidance document with estimated
concentrations at which biological effects of
contaminants including I'CHs may be observed.
l echnical guidance for use in establishing
sediment cleanup levels.
S.HIICC lliiwd on liihlc ( .1-1 >>l ll)c IMiasc I Report. updated 5/05/'lS mid
-------
Tai I
POTENTIAL ( IIEMICAL-SI'EC IKIC ARAKS AM) CRITERIA, ADVISORIES AND GUIDANCE
MEDIUM/
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CONSIDERATION IN THE RI/KS
1 SC'A Spill
Cleanup Polity
¦49 OK 761.120 - 761.1.15
To Ik' Considered
Not an AKAR but specifics allowable levels of
residual I'CIl contamination from spill cleanup.
Also used by NYSIM-C as a soil criterion.
Requirement lor cleanup to 10 ppm 1 *C"Its
in unrestricted access areas may be
relevant as guidance to some areas of site.
Source ll.iM'd on l.ihlc C M ul liic I'l.asc I Report. updated VtlW and WWK
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TABLE 2
POTENTIAL LOCATION-SPECIFIC ARARS AND CRITERIA, ADVISORIES AND GUIDANCE
MEDIUM/
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CONSIDERATION IN THE RI/FS
federal Regulatory
Requirements for
Wetlands/
lloodplains
Clean Waler Act (CWA)
Section 404 and Rivers and
Harbors Act of 1899 (40
CI R Part 230 and 33 CI R
Part 320-329)
Applicable
Under this requirement, no activity that adversely
effects a wetland shall be permitted if a practicable
alternative that has less effect is available. II there-
is no other practical alternative, impacts must be
miligaled. A permit is required lor construction of
any structure in a navigable waler. Section 307,
diluent standards of l-ppb concentration of PCB,
is incorporated into this section by reference.
During the identification, screening, and
evaluation of alternatives, the effects on wetlands
are evaluated. ITIluent levels will be used as
guidance levels to which alternatives will be
evaluated.
KCRA Location Standards
(40 CI R 264.18)
Relevant and
Appropriate
This regulation outlines the requirements for
constructing a KCRA facility on a 100-year
lloodplain.
A facility located on a 100-year lloodplain must
be designed, constructed, operated, and
maintained to prevent w ashout of any hazardous
waste by a 100-year llood, unless waste may be
removed safely before lloodwater can reach the
facility or no adverse effects on public health and
the environment would result if washout
occurred.
TSCA facility requirements
(40 CI R 761.65 - 761.75)
Applicable
Establishes siting guidance and criteria for storage
(761.65), chemical waste landfills (761.70), and
incinerators (761.75).
Land disposal facilities should not be in 100-year
lloodplain: not hydraulically connected to surface
water bodies.
Federal
Nouregulatory
Requirements lor
Wetlands/
lloodplains
Executive Order 11990
(Protection of Wetlands);
40 CI R Part 6, Appendix A,
mandated by LPA's 1985
Statement of Policy on
Wetlands and I'loodplains
Assessments for Cl.RCI.A
Sites.
To Ik-
Considered
Under this regulation, federal agencies are
required to minimize the destruction loss or
degradation of wetlands, and preserve and
enhance natural and beneficial values of wetlands.
Remedial alternatives that involve construction
must include all practicable means of minimizing
harm to wetlands. Wetlands protection
considerations must be incorporated into the
planningand decision-making about remedial
alternatives.
Executive Order 11988
(lloodplain Management)
To Ik-
Considered
f ederal agencies are required to reduce the risk of
Hood loss, minimize 'mpacl of Hoods, and restore
and preserve the natural and benellcial values ol
floodplains.
Evaluate potential effects of actions to ensure dial
planning and decision-making consider lite effect
of the 100-year and 500-year floodplains and
lloodplain management, including lloodplain
preservation and/or lestoration.
Sonne: It.iMil on I iihlc ( .1-2 ol lite- I'luisc I Kcpuri: iip«liilii) .V0.V>>5 iini)«)/).")«
-------
TABLE 2
POTENTIAL LOCATION-SPECIFIC ARARS ANI) CRITERIA, ADVISORIES AND GUIDANCE
MEDIUM/
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CONSIDERATION IN THE RI/FS
New York Stale
1 resh wiiicr Wei lands
law
ECI. Article 24 & 71 in
Title 23; 6 NYl'KK Part 665
Applicable
Regulates activities conducted in a wetlands area
to ininiini/c (lie destruction, loss or degradation of
the wetlands
Remedial alternatives that involve construction
must include means lo protect wetlands
New York Slate
freshwater Wetlands
Permit Requirements
Regulations
6 NYC'RR Part 663
Applicable
Regulates the procedural requirements to be
followed in undertaking different activities in
wetlands and in areas adjacent lo wetlands.
Remedial alternatives thai involve construction
must include means to protect wetlands No
permit required for C 1 RC'I.A but actions must
meet substantive requirements
NY Stale 1 loodplain
Regulations
6 NYCRR 372-2
Applicable
Establishes construction requirements for
hazardous waste facilities in 100-year lloodplain
Potentially applicable for remedial activities if
conducted within lloodplain
Endangered Species
Act of IV73. as
amended. fish and
Wildlife
Coordination Act
16 USC 1531;
16 IISC 661
Applicable-
federally supported actions are required to not
jeopardize the continued existence of
endangered'lhrealencd species or adversely
modify or destroy the critical habitats of such
species. Consultation with NOAA/NMI S and
USIWS required (Section 7 consultation)
Potential ARAR as threatened or endangered
species (shortnosc sturgeon) may inhabit the she
downstream of the potential remediation area
(Esopus Meadows area in the l.ower Hudson
estuary)
farmland Protection
Policy Ad ol I48I
(IPPA)
7 USC 4201 ci mi
Applicable
Regulates the extent lo which federal programs
contribute to the unnecessary and irreversible
conversion of farmland to non-agricultural uses.
Potential ARAR for remedial alternatives
Endangered and
Threatened Species
ol l isli and Wildlile
Requirements
6 NYeRR 182
Applicable
Restricts activities in areas inhabited by
endangered species.
Potential ARAR as many lisli and wildlife
species inhabit the site
National Historic
Preservation Acl
PL 84-655; 33 CER
Part 800
Potentially
Applicable
Proposed remedial actions must lake into account
effect on properties in or eligible for inclusion in
the National Registry ol Historic Places
Presence of National l andmarks and NKIIP sites
lo be determined.
Wild and Scenic
Rivers Acl
16 USC 1271-1272;
40 CI-'R 6.302
Potentially
applicable
Selected rivers of the Nation and their immediate
environments shall be protected lor the benefit and
enjoyment ol present and future generations.
Wild or scenic status lo he determined
Designation made by Slates using Icdcral ciilciia
No! applicable it Hudson River pio|ccl aiea is not
designated as wild and scenic river
SmiKt II.im.iI on l abk-c !: nl Hit I'Iimm: I Report. ii|Kj;ikd Vtl>/>> .mil'//V)X
-------
TABLE 2
POTENTIAL LOCATION-SPECIFIC ARAKS AND CRITERIA, ADVISORIES AND (iUII)ANCE
MEDIUM/
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CONSIDERATION IN TIIE RI/FS
NY Wild. Scenic,
and Recreational
Rivers Act and
Regulations
i:C l. Article 15. Title 27; 6
NYCRR I'art 666
Potentially
applicable
Similar to federal act but adds additional category
of "recreational"
Presence of wild, scenic, and recreational rivers
to be determined
NY Industrial
1 la/ardous Waste
1 acilit) Siting Hoard
6 NYt'RK I'art 361
Potentially
applicable
1 la/ardous waste management facilities must
obtain a certificate from the board before a new
facility can be sited.
To be determined.
Source IliiMilon tablet 1-2 >>l llic l*li;«-*c I Report. u|>d.ilcl v'tHMS ami W WH
-------
TABLE J
POTENTIAL ACTION-SI'KCIKIC ARAKS
AKAK
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARARS
IK A REMEDY IS SELECTED KOR WHICH TIIK.SK.
REQUIREMENTS ARE ARAR
Toxic Substances Control Act ( 1 SCA) -
Chemical Waste landfill Requirements
(40 CIR 761.75)
fstablishcs approval and technical requirements lor land
disposal (landlllling) of PCMs
l andfills must be approved by Regional administrator,
soil/liners permeability 10 7cm/sec. must have groundwater
monitoring, leachate collection and monitoring, etc
I SC A - Incineration Kci|iiircincnls (40
C I K 761.70)
fstablishcs rec|iiirements lot thermal destruction of I'CHs in
incinerators (boilers not permitted lor non-liquid I'CHs or
dredged material)
Incinerators must be approved (trial burn at discretion of
regional administrator) lor non-liquid I'CHs, combustion
efficiency must be |)RI feed, slack gas,
and operation monitoring required; shutdown required if
monitoring fails.
1 SC'A - Storage requirements (40 CTR
761.65)
fstablishcs technical requiicincnts I'or temporaiy storage of I'CH
wastes prior to treatment or disposal
Must have roof, curbing, impervious lloor; check monthly; not
allowed in 100-year lloodplain Proposed revision would also
allow storage in RCRA facility.
RCRA - General facility Standards (40
CIR 264.10 - 264 IS)
General facility requirements outline general waste analysis,
security measures, inspections and training requirements.
Any facilities will be constructed, fenced, posted and operated
in accordance with this requirement. All workers will be
properly trained. Process wastes will be evaluated for the
characteristics of hazardous wastes to assess further landlilling
requirements.
RCRA - Preparedness and Prevention
(40 CI R 264.30 - 264.31)
1 his regulation outlines requirements lor safety equipment and
spill control
Safely and communication equipment will be installed at the
site; local authorities will be familiari/.ed with site operations
RCRA - Contingency I'lan and
l-mergency Procedures (40 C'l'R 264.50 -
264.56)
1 his regulation outlines the requirements lor emergency
procedures to be used follow ing explosions, fires, etc
Plans will be developed and implemented during site work
including installation of monitoring wells, and implementation
of site remedies.
RCRA - Releases from Solid Waste
Management Units (40 CI R 264.')0 -
264 I0'>)
This regulation details requirements for a groundwater
monitoring program to be installed at the site.
A groundwater monitoring program is a component of all
alternatives. RCRA regulations will be utili/ed as guidance
during development of this program.
RCRA - Closure and Post-closure (40
CI R 264.1 10 - 264 120)
This regulation details specific requirements for closure and
post-closuie of hazardous waste facilities.
1 hose parts of the regulation concerned with long-term
monitoring and maintenance of the site will he incorporated
into llic design
Source liii\cd chi 1 «iblc ( ol l)>c Pliiisc I Report, updiilcd iind *h l.'JK
-------
TABLE 3
POTENTIAL ACTION-SI'ECIEIC ARAKS
AKAR
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARARS
IK A REMEDY IS SELECTED EOR WHICH THESE
REQUIREMENTS ARE ARAR
KC'KA - Surface Impoundments Items
(40 C I R 264 220- 264.24'))
t his regulation details the design, construction, operation,
monitoring, inspection and contingency plans for a KCKA
surface impoundment. Also provides three closure options for
CIRCI A sites; clean closure, containment closure, and alternate
closure
To comply with clean closure, owner must remove or
decontaminate all waste. To comply with containment closure,
the owner must eliminate tree liquid, stabilize remaining waste,
and cover impoundment with a cover that complies with the
regulation. Integrity of cover must be maintained, groundwater
system monitored, and runoff controlled To comply with
alternate closure, all pathways of exposure to contaminants
must be eliminated and long-term monitoring provided
KC'KA - Wiisie Piles (40 (IK 264.250 -
264 26'))
Details procedures, operating requirements, and closure and
post-closure options for waste piles. If removal or
decontamination of all contaminated subsoils is not possible,
closure and post-closure requirements for landfills must be
attained.
According to RCRA, waste piles used for treatment or storage
of non-containerized accumulation of solid, non-llowing
hazardous waste may comply with either the waste pile or
landfill requirements. The lcm|torary storage of solid waste on-
site, therefore, must comply with one or the other subpart
RCRA - 1 anil fills (40 IT R 264 .100 -
264.3.V))
This regulation details the design, operation, monitoring,
inspection, record keeping, closure, and permit requirements, for
a KCKA landfill
Disposal of contaminated materials if determined to be RCRA
characteristic hazardous wastes farm the river would be to a
KCRA-pcnnittcd facility that complies with RCRA landfill
regulations, including closure and post-closure. ()n-site
disposal would include a KCKA-designed cap
KCKA - Incinerators (40 CI R 264.340 -
264 .W))
1 his regulation specifies the performance standards, operating
requirements, monitoring, inspection, and closure guidelines of
any incinerator burning hazardous waste.
On-site thermal treatment must comply w ith the appropriate
requirements specified in this subpart of KCKA. if determined
to be RCRA characteristic hazardous wastes.
KCKA - Miscellaneous llnils (40 CI R
264.600 - 264 'W)
These standards ate applicable to miscellaneous units not
previously defined under existing RCRA regulations lor
treatment, storage, and disposal units.
Units not previously defined under RCRA must comply with
these requirements.
Source Itiiscil .hi hihlc C M «>l the I'h.isc I Kcporl. upit.iliil 5/(>>/')5 iirul'».»/'»X
-------
TABLE 3
POTENTIAL AC TION-SPECIEIC AKAKS
ARAR
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN AKAKS
IE A KEMEDY IS SELECTED EOK WHICH THESE
REQUIREMENTS ARAR
1 SCA Disposal Requirements (40 CTR
Part 761 60)
Liquid 1 'C Iis at concentrations greater than 50 ppni. hut less than
500 ppm, must be disposed ol either in an incinerator, or in a
chemical waste landlll 1. or by another technology capable ol'
providing equal treatment Liquid PC lis at concentrations
greater than 500 ppm must be disposed of in an incinerator or
treated by an alternate technology capable of equal treatment
Dredged materials with PCIl concentrations greater than 50 ppm
may be disposed ol by alternative methods which are protective
of public health and the environment, if shown that incineration
or disposal in a chemical waste landfill is not reasonable or
appropriate.
PCIl treatment must comply with these regulations during
remedial action. Proposed revision to 40 CTR 761 clarifies that
approval of Regional Administrator is required for any disposal
method other than incineration per 761.70 or landlllling per
761 75 Only requirements applicable to non-liquid PC lis and
dredged material are likely to be applicable for the Hudson
River site.
OSIIA - General Industry Standards (20
CI R Part 1010)
These regulations specify the 8-hour time-weighted average
concentration for various organic compounds. Training
requirements for workers at hazardous waste operations are
specified in 20 CTR 0010 120
Proper respiratory equipment will be worn if it is impossible to
maintain the work atmosphere below the specified
concentrations. Workers performing remedial activities would
be required to have completed specified training requirements.
OSIIA - Safety and Health Standards (29
CI R I'art 1026)
This regulation specifies the type of safety equipment and
procedures to be followed during site remediation.
All appropriate safely equipment will be on-site In addition,
safety procedures will be followed during on-site activities
OSIIA - Record keeping. Reporting, and
Related Regulations (20 CTR 1004)
This regulation outlines the record keeping and reporting
requirements for an employer under OSIIA
1'hese requirements apply to all site contractors and
subcontractors and must be followed during all site work
C'WA - 40 CI R I'art 403
T his regulation specifies pretreatment standards for discharge to
a publicly owned treatment works (I'OI W).
If a Icachalc collection system is installed and the discharge is
sent to a PO'I'W, the I'OI'W must have an approved
prctrcatment program. Ihc collected leachalc runoff must Ik' iii
compliance with the approved program Prior to discharging, a
report must be submitted containing identifying information,
list of approved permits, description of operations. Ilovv
measurements, measurement of pollutants, certification lis a
qualified professional, and a compliance schedule.
Source on I ahlc C 1-1 ol the I'lui-c I Report, updated S/05MS and W/'IX
-------
TABLE 3
POTENTIAL ACTION-SPECIFIC ARARS
ARAR
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARARS
IF A REMEDY IS SELECTED FOR WHICH THESE
REQUIREMENTS ARE ARAR
Regulations on Disposal Site
Determinations Under the Water Ael (40
CI R 231)
1 hese regulations apply to all existing. proposed, or potential
disposal sites lor discharges of dredged or fill materials into U .S.
waters, which include wetlands.
1 he dredged or till material should not he discharged unless it
can be demonstrated that such a discharge will not have an
unacceptable adverse impact on the wetlands
IK) 1 Rules for Transportation of
Hazardous Materials (40 CI K Parts 107.
171.1-171.5)
1 his regulation outlines procedures for the packaging, labeling,
manifesting and transporting of hazardous materials.
Contaminated materials will be packaged, manifested and
transported to a licensed'oll-sile disposal facility in compliancc
with these regulations.
New York State Pollutant Discharge
Elimination System (6 NYC'RR 750-757;
TOCiS 1.3.4)
Establishes water quality standards, effluent limitations,
standards of performance, toxic effluent standards and
prohibitions, and prclrcalmcnl standards.
NYSDI.C has determined that discharges of PCMs should be
not detected, based on a practical analytical quantitation limit
of 0 3 ug/E.
New York Slate RCKA Hazardous
Waste Regulations (ft NYC'RR 370-372)
Outlines design specillcations and standards of performance for
disposal facilities and treatments. 1 loodplain requirements in 6
NYCRK 372-2
To be determined.
New York Slate RCRA Hazardous
Waste Regulations (6 NYl'RK 373)
Establishes requirements for the closure (clean closure and
waste-in-place closure) and long-term management of a
hazardous disposal facility
To be determined.
New York Stale Solid Waste Regulations
(ft NYC'RR 3ftO-3ftl)
Requirements for landfill operation and closure, incineration,
and other solid waste management activities f acility siting
requirements in 6 NYCRK Part 3ft 1.
To be determined.
New York State Air Pollution Control
Regulations (6 NYC'RR 200-221)
Establishes maximum ambient levels lor criteria pollutants and
establishes emissions limitations for sources which emit VOCs
into the air.
To be determined. I'Clis are not VOCs NYSDIC Division ol
Air Resources Air Ciuide-I may be applicable to I'CH
emissions
NY Environmental Conservation Law,
Title 15
Regulates excavation and till of the navigable waters of the
stale.
t o be determined, applicable to consideration of any alternative
involving dredging or tilling
Source lliiscilini l.ihlcl \oMhc I'lwisc I Report, updated 5/OV>5 and <>WK
-------
TABLE 4
INITIAL IDENTIFICATION OF GENERAL RESPONSE ACTIONS
AND REMEDIAL TECHNOLOGIES
GENERAL RESPONSE ACTION
REMEDIAL TECHNOLOGY
1 NO ACTION
None (with or w ithout continuation of existing
monitoring and institutional controls)
2 MONITORED NATURAL
ATTENUATION
None (with continuation of existing monitoring
and institutional controls or additional monitoring
and institutional controls)
3 CONTAINMENT
Subaqueous Capping
Retaining Dikes and Berms
Ground Freezing
4 IN SITU TREATMENT
Bioremediation
Solidification/Stabilization
Dechlorination Solidification
Solvent Extraction
Chemical Dechlorination
5 REMOVAL
Environmental Dredging (with or without
dispersion controls)
Excavation
SEDIMENT PRETREATMENT
Dewatering
Solids Classification
DISPOSAL
Beneficial Use
Land Disposal (Landfills)
Confined Disposal Facility
6 REMOVAL
Environmental Dredging (with or without
dispersion controls)
SEDIMENT PRETREATMENT
Dewatering
Solids Classification
EX SITU TREATMENT
Dechlorination
Solvent Extraction
Thermal Desorption
Combined Physical Chemical
Incineration
Soil Washing
Bioremediation
Solidification Stabilization
Dechlorination Stabilization
DISPOSAL
Beneficial Use
Land Disposal (Landfills)
Confined Disposal Facility
Note: Response action numbering on this table corresponds to numbering in Section 2.3.
-------
FIGURES
-------
Geochemical Models
Ecological Models
1 Balded p»0> *r°«w and shaded boxes indicate the model iteration
oop (or the development of remedial action objectives
TAMS Coo»i*ams Inc
Figure 1
Hudson River PCBs Reassessment Feasibility Study Modeling Analysis Flowchart
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