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PCBs SUPERFUND SITE
Engineering Performance Standards
General Overview
Winter 2011 Update
Highlights
This fact sheet describes the objectives and intended use of engineering performance standards for the
Hudson River PCBs Superfund site. These standards were released to the public for review and
comment, and were evaluated by an independent panel of scientists and with input from a broad range
of stakeholders. Additional information can be found in individual fact sheets and in more detailed
documents on dredging-related resuspension, dredging residuals, and dredging productivity.
Background
In February 2002, EPA issued a Record of Decision
(ROD) for the Hudson River PCBs Superfund site that
calls for targeted environmental dredging of
approximately 2.65 million cubic yards of PCB-
contaminated sediment from a 40-mile section of the
Upper Hudson River.
The Hudson River cleanup will achieve five objectives:
•	Reduce cancer risks and non-cancer health
hazards to people who eat fish from the
Hudson River by reducing the concentration
of PCBs in fish,
•	Lower the risks to fish and wildlife by reducing
the concentration of PCBs in fish,
•	Diminish PCB levels in sediments in order to
reduce PCB concentrations in river water that
are above water quality standards,
•	Reduce the quantity (mass) of PCBs in
sediments that may be consumed by fish and
wildlife, and
•	Minimize the long-term movement of PCBs
down river.
Dredging will occur in two phases:
•	Phase 1 dredging took place from May to
November 2009 along a six-mile stretch of the
Upper Hudson River near Fort Edward, NY
Phase 1 dredging was conducted at a
reduced scale with extensive monitoring to
ensure that it was done safely.
•	Phase 2 dredging began in June 2011 and is
being conducted at full production to remove
the remainder of the contaminated river
sediments targeted for dredging.
What are Engineering Performance
Standards?
Engineering performance standards are technical
requirements to help ensure that the cleanup meets
the objectives for protecting peopled health and the
environment set forth in the ROD and does not
cause adverse health or environmental impacts.
They have been developed to make sure the
dredging is done safely and stays on schedule. The
ROD required the development of the following
engineering performance standards:
•	Dredging-related resuspension (transport of
PCBs down river);
•	Dredging residuals (PCBs left behind); and
•	Dredging productivity (complete the project
efficiently)

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Dredging-related Resuspension
The resuspension standard and action levels are
used to control RGB concentrations in the river
downstream of the dredging to protect public water
intakes and to minimize the impact of dredging-
related releases on the recovery of the Hudson
River ecosystem. A water quality-monitoring
program is in place to show that the objectives of
the resuspension standard have been met during
dredging. Sampling results are used to determine
whether additional measures are needed to ensure
protection of public health and the environment. If
necessary, these measures could include
expanding the monitoring program, implementing
operational or engineering improvements to reduce
resuspension levels or temporarily slowing or
stopping the dredging.
For the dredging project, the resuspension standard
is the control level of 500 parts per trillion (ppt) Total
PCBs, the EPA drinking water standard under the
Safe Drinking Water Act. Prior to Phase 1 dredging,
EPA used extensive modeling, environmental
dredging case study data, and federal and state
water quality standards to develop a series of tiered
action levels for the standard. Computer models
were used to simulate PCB concentrations in water,
sediment and fish tissue that could result from
dredging resuspension. The modeling efforts
examined the impact of allowing dredging
operations to proceed at various action levels
specified in the resuspension standard. The
conclusion was that operating at low resuspension
rates resulted in negligible impacts on PCB levels in
fish tissue. Higher resuspension rates could
I	m
increase fish tissue concentrations during dredging,
but these were not found to be significant after
dredging was completed.
If there is a single exceedance of the Resuspension
Standard at one of the monitoring stations located
downstream of dredging operations, EPA may require
GE to conduct evaluations of the dredge operations
and/or implement best management practices. If the
500 ppt Total PCBs standard is exceeded for five
days out of any seven-day period or there is a
confirmed exceedance at Waterford, EPA may require
GE to slow down or shut down dredging operations
upstream. If a slowdown or shutdown is required,
normal operations will typically resume when the
concentration at the applicable monitoring station is
below 500 ppt Total PCBs for two consecutive days.
Dredging Residuals
The residuals standard is designed to detect and
manage small amounts of contaminated sediments
that may remain on the river bottom after dredging.
These "residuals" may consist of contaminated
sediments that were disturbed but escaped capture
by the dredge, resuspended sediments that were
redeposited or that settled, and/or contaminated
sediments remaining below the dredging cut lines
because they were not detected by the sediment
sampling program.
The residuals standard first requires post-dredging
sampling and analysis to detect and characterize
PCB concentrations in the residual sediments. The
level of PCBs in the sediment samples is then
evaluated against a level of approximately 1 part per

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million (ppm)- the sediment cleanup objective for
the project - and a series of statistical action levels.
If the sampling results do not meet the action levels,
the appropriate management approach to the
residual sediments, such as capping or redredging,
will be selected to achieve the cleanup goals while
maintaining dredging productivity.
Dredging Productivity
The productivity standard is designed to keep the
dredging work on track to meet the goal of
completing the project on schedule. The
productivity standard defines the total project
sediment volumes to be dredged each dredging
season, based on the current estimate of cubic
yards of sediment to be removed. Maintaining an
appropriate dredging production rate will help to
clean up the river within a reasonable time frame.
How were the standards developed?
The engineering performance standards were
developed to provide public accountability and
assurances that the dredging will be protective of
people's health and the environment. These
standards will be used to measure the progress of
the dredging and its effect on the river system.
They will ensure that:
•	Action levels established in the resuspension
standard protect people's health and the river
ecosystem and maintain the total amount of
PCBs in the river during dredging operations,
•	PCB amounts and concentrations allowed by
the resuspension standard are set at levels
that do not cause additional serious long-
term impacts on PCB levels in fish in the river,
•	Removal of PCB-contaminated sediments
with an anticipated residual of approximately
1 ppm prior to backfilling is achievable on an
area-wide average basis, and
•	The cleanup can be accomplished within a
reasonable timeframe without compromising
the other engineering performance
standards.


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Visit, call, or write to the Hudson River Field Office at the address below or log on to www.epa.gov/hudson.
EPA Hudson River Field Offi
Larisa Romanowski
Public Affairs Specialist
Hudson River Field Office
421 Lower Main Street
Hudson Falls, NY 12839
(518) 747-4389 or
(866) 615-6490 Toil-Free
romanowski.larisa@epa.gov
Team:
Dave King
Director
Hudson River Field Office
421 Lower Main Street
Hudson Falls, NY 12839
(518) 747-4389 or
(866) 615-6490 Toil-Free
king.david@epa.gov
Gary Klawinski
Project Manager
Hudson River Field Office
421 Lower Main Street
Hudson Falls, NY 12839
(518) 747-4389 or
(866) 615-6490 Toil-Free
klawinski.gary@epa.gov
The Field Office hours are Monday - Friday 8:00 am - 4:30 pm, with evening hours by appointment.

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