Document VQ3rjqL3VrkQRxajV3keXBON

ENVIRONMENTAL IMPACT STATEMENT ON THE HUDSON RIVER PCB RECLAMATION DEMONSTRATION PROJECT SUPPLEMENTAL DRAFT AUGUST, 1981 U.S. ENVIRONMENTAL PROTECTION AGENCY REGION II 26 FEDERAL PLAZA H0NS 0092M NEW YORK, NEW YORK 10278 CHAPTER 1 introduction HONS 009289 ERRATA dw cater peri for this draft amfpefTAL ENviRoferot wot sraieeir MIL BO OCTCBER13,1981 NOT OCTOBER 6,1981 AS STATED IN TIE ATTAQ0 COVER LETTER. MOWS 009290 CHAPTER 1 INTRODUCTION The purpose of this Supplemental Draft Environmental Impact Statement Is to respond to comments received from the public concerning the Draft Envlroneental Impact Statement (DEIS) on the Hudson River PCS Reclamation Demonstration Project Issued on May 8, 1981. Comments were received during the three public hearings and during the 45 day public review period for the DEIS. This Supplemental DEIS also serves to modify parts of the text of the DEIS based on comments and recently acquired Information. Included In this Supplemental DEIS as an appendix Is the Response to the Executive Summary prepared by the New York Department of Environmental Con servation (NSYDCC). This docuaent Includes a description of the monitoring and contingency plans that would apply if the recommended project Is Implemented. I. Summary of Public Hearings Three public hearings on the DEIS were held at the following locations mid times: -- ------ June 23, 1981: 7:00 PM Washington County Courthouse Route 4 and Maple Road Hudson Falls, N.Y.. June 24, 1981: 7:00 PM Dutchess County Community College Pendell Road Poughkeepsie, N.Y. June 25. 1981: 6:30 PM 2 World Trade Center Main Hearing Room, 44th floor New York. N.Y. Public notice of these hearings was made available through an Environmental Protection Agency (EPA) notification as well as through news releases In local HONS 009291 1-1 newspapers In Albany, Poughkeepsie, and New York. The Meetings were co-chalred by the EPA and the Army Corps of Engineers (COE). Representatives of EPA, the COE, and WAPORA, Inc. participated In the presentation and were available to answer questions and comments. EPA and COE opened the hearing with a brief synopsis of the purpose of the hearing and format. WAPORA, Inc. followed with a presentation of the key project Issues, findings of the OEIS, and recommendations. EPA Invited all parties to make ccmnents during the hearing and submit any additional written comments on the DEIS or COE permit to EPA prior to July 6, I960. The following Is a summary of comments made at the public hearing or received after the public hearing during the 10 day comment period. Responses to comments are contained In Chapter 3 of this report, and a complete list of organizations and Individuals from which comments were received Is on pages 4-1 and 4-2. 1. HUOSOH FAILS PUBLIC HEARING Most of the comments expressed at the Hudson Falls public hearing were In opposition to the proposed project. Verbal and written comments were sub mitted by local government representatives, farmers and landowners with property near the proposed containment site, and other concerned organizations and Individuals. The Citizen-Environmentalists Against Sludge Encapsulation (CEASE, Inc.) expressed disapproval of the site and presented preliminary results of a poll they conducted of public opinion about the proposed project. The PCS Project Citizens Advisory Committee (CAC) presented comments and recommendations but had not yet taken a position for or against the project. The New York Farm Bureau and the Warren-WashIngton County Farm Bureau expressed oposItion to the project. The main areas of concern raised at the hearing were: a Too little emphasis given to agriculture In the OEIS; Potential reduction In property values, especially for farms, near the containment site; a Public health concerns about the dredging and containment operations; HONS 009292 1-2  Long-term stability of the containment site; a The need for detailed monitoring and contingency^plans for the project; a Possibility of detoxification of dredge spoils Instead of long-term containment; and a Presence of trace contaminants associated with PCBs at the containment site. 2. POUGHKEEPSIE PUBLIC HEARING Almost all comments at the Poughkeepsie Public Hearing were In support of the project, although most approvals were expressed with concerns and recom mendations. Several major environmental groups gave conditional approval of the project. Including: a Sierra Club a Hudson River Fishermen's Association a Scenic Hudson a Clearwater, Inc. a National Audubon Society. Host of the comments and recommendations concerned the following subjects: a Preference for the full-scale project, but qualified approval for the reduced-scale project; a Safety of downstream drinking water supplies during and after dredging operations; a Need for Identification and mitigation of the unknown source of PCBs in the upper Hudson River; a Need for detailed monitoring and contingency plans for the project; a Importance of continued monitoring of fisheries; a Education of local people about potential hazards of eating contaminated fish; a Need for team of experts to oversee all phases of the project; and e Urgency of Implementing the project as soon as possible to avoid further dispersion of hot spots. 1-3 HONS 009293 3. NEW YORK CITY PU8UC HEWING Comments received at the New York City Public Hearing were generally In aupport of the recomended project, although most approvals were expressed with coaments and recommendations. The following organizations gave full or conditional approval: e The Port Authority of New York and New Jersey e New York City Department of Ports and Terminals a Save Our Port e International Union of Operating Engineers Local 251 e Seafarer's International Union United New York and New Jersey Sandy Hook Pilots Association. The Natural Resources Defense Council, Inc., raised a variety of Issues about PC8 transport mechanisms In the Hudson River, wetland hot spots, monitor ing, and other subjects they believed were not adequately addressed in the OEIS. Most comments and recommendations made by organizations and Individuals at the hearing Involved the following subjects: e Concern about PC8 contamination of New York Harbor sediments, and Implications for future maintenance dredging and ocean disposal of spoils; e Underestimation In DEIS of major benefits of the proposed project for New York Harbor; e Concern over drinking water supplies taken from the Hudson River; e Need for detailed monitoring and contingency plans for the project; e Preference for the full-scale project, but qualified approval for the reduced-scale project; e Need to Identify the unknown source of PCBs In the upper Hudson River; e Need to assess the stability of remnant deposits. 1-4 HONS 009294 2. Page 1-10 The first sentence of the first paragraph Is revised as follows: All fishing In the Hudson River between Port Edward and the Troy Daw Is prohibited. 3. Page 2-5 First paragraph, first sentence, is modified as follows: The bioassay matrix presently used by EPA, the COE and the United States Fish and Wildlife Service (USFWS) far determining the viability of ocean disposal of PCS contaminated sediments Indicates that organisms are pre sently showing uptake from sediments In the 1 ug/g (ppm) and below range. A flood event could cause concentrations to Increase to levels which would preclude ocean duaplng. 4. Page 2-2S The following sentences should be added to the second paragraph: An access road to remnant deposit 3 already exIstF. It was constructed for the removal of remnant deposit 3A In 1978. 5. Page 2-40 The following paragraph should be inserted after paragraph three: Franklin Research Institute, Philadelphia, Pennsylvania, has recently developed a process which could detoxify PCB contaminated materials. In this process, a polyethylene glycol reagent 1$ used to strip the PCB molecule of chlorine atoms. The sodlim In the reagent then combines with the chlorine to form a salt. The biphenyl molecula can then be broken down 2-2 HONS 009295 by bacteria In a landfill. This process Is still pending approval by CPA. EPA plans to evaluate the process in the near future with tests on PCBcontamlnated soils. If successful, the process will also be evaluated with Hudson River sediments by EPA laboratory tests. Depending on these test results, the cost-effective feasibility of the process for a full-scale application will be determined. 6. Page 2-43 The third paragraph, first sentence. Is revised as follows: During each dredging season, the proposed site would receive spoil from the dredging operations. The maximum dredging season will extend from Hay through November of each year. 7. Page 3-17 The second paragraph, last sentence. Is revised as follows to reflect the 1980 EPA criteria for PCBs: Replace 0.16 ug/1 (ppb) with 0.079 ng/1 (ppt) for a lifetime cancer risk of one in one million. 8. Page 3-27 The following sentence should be added to the end of the first paragraph under the section entitled *1980 Fisheries Data*: Latest preliminary data from NYSDEC Indicate that PCB levels in pumpkinseed sunflsh In the upper Hudson River have Increased substantially in the last year (Plrone, PCB Settlement Advisory Committee, June 24, 1981). NYSOEC Is presently Investigating the reason for this increase. 2-3 HONS 009296 13. Page 4-59 The last two sentences of the first paragraph should be deleted and replaced with: The possible use of such measures results from an air quality analysis performed by WAPORA, using extremely adverse meteorological conditions and emissions estimates developed by HydroQual (Appendix J), which Indicated the potential for a violation of the NYSDOH guideline. However, under normal meteorological conditions and dredging conditions. It Is predicted that the NYSDOH guideline will not be exceeded with any regularity. 14. Page 4-63 The first paragraph, first sentence, is modified as follows: ...the PCB levels In the various crops...should be monitored at approxi mately 100 m (330 ft) Intervals to a distance from the containment site at which all foliar PCB levels reach background levels of forage. The last sentence Is deleted and replaced with the following: Buckley's work also indicates that background levels will be reached at ZOO n (650 ft) from the containment site and monitoring should be carried out to this distance. II. AIR QUALITY ANALYSIS An air quality analysis was performed by HAPORA, Inc., as part of DEIS In order to assess the effect of PCB volatilization from the proposed containment site on ambient concentrations of PCBs downwind of the site. To be consistent with the NYSDOH proposed guideline of 1 microgram (ug)/cub1c meter (cu m) ave raged over a 24-hour period (Appendix I of the DEIS), "worst case" concentrations of PCBs were predicted at residences nearest the containment site. Below Is a review of the methods used in the air quality analysis. 2-5 HONS 009297 The general approach followed In performing this analysis was to Identify a series of worst case conditions or values for each of the various emission. Meteorological, and site operation parameters used In modeling the dispersion of PC8s as an airborne pollutant, and then to determine maximum PCS concentrations assuming that these worst case values occur simultaneously. Whenever It was necessary to make assumptions in quantifying these parameters, preference was given to the particular assumption that would lead to an upper bound of all possible-impacts rather than to an average Impact. Maximum pollutant concen trations obtained following this approach therefore conform to the intent of the NYSDOH recommendation, which specifies a concentration not to be exceeded. While It Is theoretically possible that. Individually, any of these worst case conditions might occur during the filling of the containaient site and before It is capped, it is extremely unlikely that all of these conditions would occur simultaneously, as assumed In the analysis. Consequently, the PCB concentrations can properly be Interpreted as representing an upper bound on the maximum values possible. Actual concentrations are expected to be considerably below the theoretical worst case values presented. Ambient pollutant concentrations at a receptor are affected by the emission Strength of the pollutant as it leaves the source, the vertical and horizontal distance between the source and receptor (as well as by the presence of ob structions or Irregular terrain features between the two), and the prevailing meteorological conditions during the time the pollutant is dispersed. Air quality models, which are mathematical representations of how these various factors combine to determine downwind ambient concentrations, are commonly used to estimate present and future pollutant concentrations. The following para graphs briefly discuss the methodology. Including the dispersion model. Input data and assumptions, which lead to the prediction of worst case PCB concen trations. EPA's PTMPT computer dispersion model, normally used to model emissions from point sources of pollution, was adopted to this study by: 1) suppressing the plume rise feature of the model so that the effective "stack heights* of the 2-6 MOWS 009298 sources are near ground level; 2) dividing the containment site Into 25 cells, each with Its own emission rate (depending on cell size and turbulence}; and 3) modeling each cell as a "virtual point source" of pollution. These virtual or Imaginary sources represent the upwind locations where each pollutant plume would have to originate from a stack In order to reach the horizontal dimensions of the containment cell on Its way to a downwind receptor. Figure 4-1 shows the model ing of the containment site as emission cells, the location of the ne*est residence, and the direction of the critical wind angle, which was found by the computer model to maximize PCS concentrations at the receptor. Since there are no meteorological data for the containment site environs, and since the complex geography of the area precludes the use of data from Albany or Glen Falls, the most severe (from an air pollution standpoint), yet plausible, wind speed, wind direction and stability class conditions were selected for the analysis. The wind was assumed to blow at a steady speed of 1 m/sec and to vary only 12 degrees to either side of the critical or maximizing wind angle over the 24-hour period. Stability class, which Is an empirical Indication of atmospheric turbulence as measured by the change In wind speed and direction with altitude, was assumed to be of category E (very stable). The air quality aiodellng analysis was conducted using "dummy" emission rates of 1000 ug/m^-hr for all cells save the one nearest receptor (cell no. 17), when a rate of 10,000 ug/square meter (sq m) - hr). was used to approximate tne emissions under turbulent conditions of spoil pipe material stirring the cell. When a more rigorous study of emissions was conducted (see Appendix J of the DEIS), the resulting refined emission estimates were used simply to apply a linear factor to the predicted concentrations. This simple adjustment Is made possible by the one-to-one relationship between concentrations and emissions. III. SUHHARY OF IMPACTS FUR THE RECOHMEHOEP PLAN Table 2-1 is a summary of the significant impacts, both beneficial and adverse, that would be associated with the recommended plan. The purpose of the table Is to provide a brief review of potential Impacts, and the reader should 2-7 HONS 009299 refer to Chapter 4 of the DEIS for a more detailed discussion of Impacts. Impacts of the full-scale project would be similar in nature to those of the reduced-scale project, but they would differ In degree. The full-scale project would have greater long-term benefits, and also have greater short-term adverse Impacts, because more hot spots and a larger quantity of PCBs would be removed from the Hudson River. 2-8 HONS 009300 Table 2-1 IMPACT SUMMARY OF RECOMHENOEO PLAN1 Component e In-river containment of hot spots e In-place containment of remnant deposits Beneficial Adverse Short-term: none Short-term: potential health risk to workers e annoyance from construction noise damage to benthic communities localized destruction of wet . lfnds e suspension of PCB-laden sediments. Long-term: Long-Term: e prevent erosion of hot spots, decreasing PCB contamination of river e changes In drainage of wet -- lands, perhaps reducing their value. - protect downstream water supply - decrease PCB uptake by ecosystems - Increase potential for reopening fishery - decrease threat to conti nuation of maintenance dredging and ocean dis posal of spoils. Short-term: none Short-term: e potential health risks to nrkers and public e annoyance from construction and traffic e temporary Increases in PCB losses to air and river e destruction of vegetation at access roads and deposits Note 1. Potential impacts of the full-scale and reduced-scale projects are similar but differ in degree. The full-scale project would have greater long-term benefits, and greater short-term adverse Impacts, because more PCBs would be removed from the river. HONS 009301 2-9 Table 2-1 (continued) -Component_______________ , Beneficial Adverse ln-place containment of reamant deposits (cont.) Long-term: e reduce losses of PCBs to air and river - decrease risks to public health - decrease uptake to eco systems - decrease threats to con tinuation of mainten ance dredging and ocean disposal of spoils - Increase potential for reopening fishery Long-term: t potential for conta mination of river if containment fails e potential impediment to hydroelectric development Dredging of hot spots Short-term: none Short-term: a losses of PCBs and heavy metals to water e destruction of benthic organisms e adverse effects on sensitive aquatic fauna e temporary Increases in PCB volatilization e potential risk to worker heel e annoyance from construction noise e disruption of normal river traffic e possible destruction of wetla Dredging of hot spots Long-term: e reduce PCB concentrations In water and air - decrease risks to public health - Improve quality of downstream water sup plies - decrease uptake by fauna and flora - Increase potential for reopening fishery - decrease threat to con tinuation of maintenance dredging and ocean dis posal of spoils Long-term: e possible loss of wetlands e creates need for containment of contaminated dredge spoils 2-10 HONS 009302 Table 2*1 (continued) Opponent_____________ Containment Site a Containment Slta (Cont.) Beneficial Short-term: none Long-term: a PCBs prevented from dispersion through environ ment - decreased public health risks - decreased contamination of ecosystems - decrease In amount of PCBs entering lower Hudson and estuary a contaminated sediments are dewatered, concentrated and readily available for detoxification if an ef fective process becomes feasible Adverse Short-term: a volatilization of PCBs during disposal operations . a temporary increase In PCS uptake by vegetation near sit a annoyance from construction activity a Increased PCBs In river from site dewatering a potential health risk to workers and public Long-term: a minor quantities of site leachate discharged to Hudson River , a potential lower market values for adjacent propertles ; a need for long-term monitoring 2-11 HONS 009303 EXECUTIVE SUMMARY DATE: TYPE OF STATEMENT: RESPONSIBLE FEDERAL AGENCY: TYPE OF ACTION: May 1981 Supplemental DEIS U.S. Environmental Protection Agency (EPA) Region II Administrative RECOMMENDED ACTION Based on public health, environmental, cost, and engineering evaluations carried out by EPA and Its environmental consultants, the EPA recomnends that the action alternative be Implemented IF contingency/mitigation measures ensuring public safety are developed (Table S-l). Resolution of these Issues will ensure that minimal risk to public health, safety, and welfare will result from the Implementation of this project. Modifications and contingencies developed will be submitted for public comnent before a National Environmental Policy Act (NEPA) decision Is reached. EPA recommends that a project to dredge and/or stabilize all known poly chlorinated biphenyl (PCS) hot spots be Implemented. After carefully evaluating both the original full-scale proposal and reduced-scale proposal submlttted by New York State Department of Environmental Conservation (NYSOEC), EPA recamnends funding a modification of the original full-scale project, since greater po tential benefits will be realized. However, If additional funding Is not available, the reduced-scale project Is also recommended, although It offers only a reduced potential benefit, because It will provide for demonstration of river recovery and Indefinite storage while not endangering public health, safety, and welfare. As discussed below, the authorization by Congress under Section 10 of the Clean Water Act (CUA) Amendments Is 120,000,000. If the action alternative Is HONS 00930A S-l Table S-X USEPA Recommended Program Full- Scale Reduced-Scale Dredging or In-river containment of all 40 hot spot areas In the river bed with containment In a secure upland site. Design and construction of a secure upland containment site capable of Indefinite long-term Isolation of contaafnated material Deletion of remnant deposit removal and upland containment; Instead, provision of secure cap and top dressing,and further bank stabilization If necessary Elimination of provision for the con tainment of PCB-contamlnated material from dunpsltes In the Fort Edward area. Provision for containment of contaminated materials from three New York State Department of Transportation (NYSOOT) dredge spoil sites (2X2, 13 and 204 Annex) Provision for dredging and containment operational standards and procedures, mitigation measures, monitoring programs, and contingency plans necessary to safe guard public health and agricultural resources Provision for research studies/environ mental monitoring programs necessary to demonstrate the Improvement In the rate of recovery of the river and storage of contaminated material Reduction of the number of hot spots to be dredged or contained In-river Same, except for a reduction In capacity at the containment site Same Same Same Same Same S-2 HONS 009305 approved, th recommended action is to undertake the originally proposed $40,000,000 full-scale project with the required Modifications. Additional funds fro* either federal, state, or perhaps outside sources will be required to Inplament the full-scale project, while affording protection of the public health and the environment. Although not as desirable as the full-scale project, it is recoaaoended that the $26,700,000 reduced-scale project could be undertaken along with the aforementioned project aodlfIcatlons. HISTORY AND OVERVIEW Of THE EXISTING PROBLEM Polychlorinated biphenyls are a class of chemical compounds that have been used In agriculture and Industry for decades. Since 1930, the compounds, have been used principally in electrical transformers and capacitors, but they have also been used in a variety of other products Including lubricants, pesti cides, cutting oils, plasticizers, and adhesives. During a thirty-year period ending In 1977, more than 227,000 kilograms (kg) (500,000 pounds [lb]) of PCBs were discharged into the Hudson River from two General Electric (GE) capacitor manufacturing plants at Fort Edward and Hudson Falls, New York. Much of the discharged PC8s was adsorbed by the bottom sedi ments of the river and accumulated behind the Fort Edward Oam. When the dan was remnved in 1973 due to its deteriorating condition, an estimated 650,000 cu n (850,000 cu yd) of the PC8-contaminated sediments was released and migrated downstream. The downstream migration was further accelerated during flood situations, causing PCBs to concentrate in river bottom sediments from Fort Edward to New York Harbor. PROJECT DEVELOPMENT BY NYSOEC As part of an administrative proceeding between NYSOEC-and GE, approximately $3,000,000 was spent by NYSOEC to investigate the extent of PCB contamination in the Hudson River and methods to reduce and remove the threat of continued PCB contamination. ' Forty PCB "hot spots* have been Identified in the upper Hudson River, based on five years of scientific and engineering studies. Hot spots have been defined as sediments containing 50 micrograms per gram (ug/g) (parts per million [ppm] ) HONS 009306 S-3 or mot* of PCBs. PCB concentrations along the dcposltional shore range from 5 to 1,000 ug/g (ppm) In fine grained sedlients. In addltTon, five PCB-contamin ated remnant deposits have been Identified. Ramant deposits were exposed as a result of the raooval of the Port Edward Dam, which caused water levels of the river behind the dan to drop significantly. This caused once-subaerged bottom sedloents to be exposed to the atmosphere. At present, PCB concentrations in the raanant deposits range froa 50 to 200 ug/g (ppa). The Investigations conducted by NYSDEC resulted in a project which proposed to deaonstrate the feasibility of raaovlng PCB-contamlnated sediments froa the upper Hudson River and of depositing those sediments In a secure upland contain ment site. The environmental analysis, costs, engineering, and feasibility of the project proposed by NYSDEC are presented In a draft environmental impact statement (EIS) prepared In accordance with the State Environmental Quality Review Act (SEQRA). The full-scale project recommended In the draft SEQRA EIS was estimated to cost $40,000,000. Subsequent to the draft SEQRA EIS and In response to Congressional action described below, NYSOCC rescoped the originally proposed project to accommo date the $20,000,000 funding authorized by the amendments to the Clean Hater Act (CWA) [Sections 116(a) and (b)] and State matching funds. The reduced-scale project, as developed by NYSOEC, would cost $26,700,000. A comparison of the full- and reduced-scale projects Is presented In Table S-2. C0H6RESSI0NAL ACTION In September 1980, Congress passed an amendment to the CWA under Title I. Section 116(a) and (b), entitled the Hudson River PCB Reclamation Demonstration Project. Funds for this project have been authorized under Title II, Section 205(a) of the Act. Under this legislation, EPA is authorized to expend up to $20,000,000 towards a proposed demonstratlon/reclamation project for removing and disposing of PCB-contaelnated sediments from the Hudson River. Section 116(a). The Administrator Is authorized to enter Into contracts and other agreements with the State of New York to carry out a project to demonstrate methods for the selective HONS 009307 S-4 Table S-2 NYSPEC Recommended Program Full-Scale Dredging of all 40 hot spot areas In the river bed with containment In a secure upland site Oeslgn and construction of a secure upland containment site capable of long-term Isolation of contaminated materlal Excavation of two remnant deposits (areas 3 and 5) located above the former Fort Edward Dam site, and rmnval to the upland containment site Provision for containment of material from three PCB contaminated dump sites (old Fort Edward, Fort Hiller and Caputo) should removal be found more suitable than In-place containment Provision for containment of con taminated materials from three NYSOOT dredge spoil sites (212, 13 and 204 Annex) Destruction of the recovered PCBs at such time as a technologically and economically feasible procedure becomes available Provision for funding for research studies related to environmental monitoring Reduced-Scale Reduction of the rnaaber of hot spots to be dredged from 40 to approximately 20 Same, except for a reduction In In capacity at the containment site Deletion of rmanant deposit removal and upland contalnaent; Instead provision of top dressing and fencing for remnant deposit areas 3 and 5 Elimination of provision for the containment of PCB-contamlnated material from Old Fort Edward, Fort Hiller and Caputo duaip sites Same Same Reduction In the amount of funding, for research studies HONS 009308 S-5 removal of polychlorinated biphenyls contaminating bottom sediments of the Hudson River, treating such sediments as required, burying such sediments In secure landfills and Installing monitoring system for such landfills. Such demons tration project shall be for the purpose of determining the feasibility of Indefinite storage In secure landfills of toxic substances and of ascertaining the Improvement of the rate of recovery of a toxic contaminated national waterway. No pollu tants removed pusuant to this paragraph shall be placed In any landfill unless the Administrator first determines that dis posal of the pollutants In such landfill would provide a higher standard of protection of the public health, safety, and welfare than disposal of such pollutants by any other method Including, but not limited to, incineration or a chemical destruction process. (b). The Administrator Is authorized to make grants to the State of New York to carry out this section from funds allotted to such State under Section 205(a) of this Act, except that the amount of any such grant shall be equal to 75 per centum of the cost of the project and such grant shall be made on condition that non-Federal sources provide the remainder of the cost of such project. The authority of this section shall be available until September 1983. Funds allotted to the State of New York under Section 205(a) shall be available under this subsection only to the extent that funds are not available, as determined by the Administrator, to the State of New York for the work authorized by this section under Section 115 or 311 of this Act or a comprehensive hazardous substance response and cleanup fund. Any funds used under the authority of this subsection shall be deducted from any estimate of the needs-of the State of New York prepared under Section 516(b) of this Act. The Administrator may not obligate or expend more than $20,000,000 to carry out this Section. The overall goal of the Congressional authorization is to allocate funding to assist In the cleanup of the PCBs In the upper Hudson River. The specific purpose of the authorization Is to demonstrate the Improvement of the rate of recovery of a toxic contaminated national waterway by: e selective removal of PCB-eontamlnated sediments from the Hudson River e treating the contaminated sediments as required and burying those sedi ments in a secure landfill a development of monitoring and scientific studies for water quality and fish, and monitoring the landfill site The legislation also states that prior to placing any contaminated materials In a secure landfill the Administrator of EPA must first determine that the $-6 HONS 009309 placement of the pollutants In a secure landfill uould provide a higher degree of protection of public health, safety, and welfare than either leaving the PC8contaalnated sediments In place or disposing of than by any other methods. In addition, before funding under Section 116 of the CWA can be provided, the Administrator of EPA must determine that funding Is not available under Sections 115 and 311 of the Act, as well as any existing "Superfund" legislation (Compre hensive Hazardous Substance Response and Clean-Up Fund established by the Act). PURPOSE OF FEDERAL EIS With the passing of the Section 10 Amendments to the CWA In October of 1980, Congress authorized EPA to make grants to the NYSOEC In order to carry out the Intent of the 'Hudson River PCS Reclamation Demonstration Project." On January 12, 1981 EPA-Reglon II Issued a Notice of Intent (NOI) to prepare a MEPA EIS. The purpose of the NEPA EIS Is to identify and analyze any potentially significant Impacts on the quality of the huaan environment resulting from a proposed project. In addition, the NEPA EIS decision-making process provided the forum for soliciting public consents on the proposed project by conducting a series of public meetings and hearings. A twenty-one member Citizens Advisory Committee (CAC) has been formed to advise EPA on issues of public concern regarding the project. As stated In the NOI, It was EPA's Intent to evaluate further the following In the NEPA EIS: e no-action alternatives e control of river flow a In-river detoxification e In-river containment ~ e remnant deposit alternatives In the area of the former Fort Edward Dam e complete or partial dredging, combined with upland containment a dredge spoil disposal and treatment options e other alternatives concerning PC8 removal. Including alternative dredging and transport S-7 HONS 009310 These alternatives were evaluated for potential beneficial and adverse, short* and long-tern Impacts under normal-river flow, as well as flooding condi tions. The major primary and secondary Impact assessment objectives are as follows: A. Public Health 1. Protection of downstream water supply 2. Protection of groundwater In the area of the containment site 3. Reduction of PCB volatilization from river bed/bank, and remnant deposits Into the air 4. Reduction of containment site volatilization 5. Reduction of exposure through the ingestion of food B. Fisheries 1. Permanent reopening of the commercial and recreational fisheries 2. Protection of endangered species (shortnosed sturgeon) 3. Reducing the bloaccianulatlon of PCBs through the food web. 4. Protection of wetlands C. Maintenance Dredging and Navigation 1. Mitigation of future maintenance dredging and disposal probleas In the upper Hudson River as well as the estuary 2. Maintenance of a navigable waterway serving transportation needs of the upper and lower Hudson communities D. Agriculture Protection of livestock and their food sources through: 1. Reduction of river bed/bank, and remnant deposit volatilization 2. Reduction of containment site volatilization 3. Protection of groundwater in the area of the containment site used for dairy Industry purposes E. Other Impacts 1. Evaluation of impacts to future hydroelectric dam construction and usage HONS 009311 S-8 1- Oisposal of liljfcir i welfare the but not 11 The basis c *re either *nd would i aaounts of Million). 2. The propost safeguards storage of : sedluents a long-tana a 3. The propose safeguards ter* adders supplles or 4. Renoval and sedlnents s> the Hudson t 5. Renoval and "111 also re - contanlna' - public he' bank area - public bt - the neces after proi peraanent - conductl* disposal estuary - closing r River duo contactnet * endangerlr MOMS 009312 S. The public health risks associated with the no-action alternative are greater than those associated with the full- or reduced-scale alter natives. 7. The reduction In average PCS sediment concentrations in the New York harbor due to rmeoval and In-place containment of PCBs from the upper Hudson River Is expected to be relatively small. Under extreme flooding conditions or In local areas of rapid deposition, the action alternative may have a beneficial Impact on the harbor area and areas In the upper estuary such as the Albany Turning Basin. 8. As presently proposed by NYSDEC, PCS volatilization caused by the discharge of contmalnated dredged sediment into the containment site could exceed the New York State Department of Health (NYSOOH) recom mended maximum allowable 24-hour average ambient air PCS concentration at nearby residences and at other sensitive receptors under worst case dissolved PCB concentrations and meteorological conditions. However, the analysis conducted by EPA shows that with mitigation measures presented below, the 1 microgram per cubic meter (ug/cu m) ambient air guideline should not be exceeded. The modifications to the original project, as well as to the reduced-scale project referenced above. Include changes In the design, operational standards, contingencies, and long-term monitoring and maintenance. These recommendations are consistent with the Congressional Intent of Section 10 of the CWA Amendments. The purpose of these modifications Is to provide a higher standard of protection for public health, safety, and welfare during dredging and disposal operations and throughout the life of the containment site. Prior to the NEPA decision and granting of federal funds to undertake site construction and dredging, the modifications described below must be fully developed, submitted for public comment, and approved by EPA. Since neither the original or reduced-scale project contains the specific provisions to carry out financial assurances, contingencies, long-term monitor ing, operational standards and procedures, operations and maintenance, or land acquisition, the NYSDEC must obtain firm commitments for additional funding for these provisions from either state or other federal sources prior to project approval. Federal or state matching funds currently appropriated for this S-10 HONS 009313 project r not sufficient to be used for these purposes. These current funds art to be used only for dredging, site construction and closure, and a monitor ing program only for the duration of the project operations. Although there are a substantial nunber of modifications and additions to the original and reducedscale projects, most are directed toward long-term elements subsequent to con tainment' site closure, the costs of which are to be borne by New York State. Therefore, the modified project should not substantially reduce the material planned to be removed from the river. The recommended modifications to the project are specified below under the separate categories of 'Dredging, In-River Containment, and Stabilization*, 'Disposal*. 'Long-Term Storage', and 'Water Quality Monitoring*. Dredging, In-River Containment, and Stabilization 1. Study and make recommendations to maximize in-river containment of hot spots where feasible and cost effective. (This will be studied In detail during the 45-day draft NEPA EIS review period). 2. Cap/In-place stabilization and denial of access of remnant deposits 3 and 5 as an Immediate measure. 3. Maximize upriver flow regulation at Sacandaga Dam as a flood-control measure during the dredging operation. 4. Develop operational standards and procedures, mitigating measures, monitoring programs, and contingency plans to eliminate excessive volatilization and resuspension of PCB-contamlnated seciments to protect workers, residents, agricultural resources, and water supplies. 01sposal 1. Modify disposal operations at the containment site. Including the provision for smaller containment cells, addition of PCB adsorbents, and possible cell cover during loading operations to minimize vola tilization. 2. Develop operational standards and procedures, contingency plans, and monitor program surrounding the proposed containment site for the duration of the disposal operations to assure the NYSDOH 1 ug/cu m ambient air guideline, and the 0.2 ug/g (ppm) standard for crops set by the U.S. Food and Drug Administration are not exceeded. 3. Develop specific contingency plans for additional treatment of the supernatant from Initial dewatering prior to Its discharge back to the river If permit limits (to be established) are exceeded. S-ll HONS 009314 Long-Term Storage 1. Development of long-term maintenance and monitoring programs for a minimum of 30 years with periodic program review by EPA and NYSDOH. 2. Contingency plans for (a) long-term leachate collection and treatawnt, (b) landfill cap maintenance, (c) excessive PCB volatilization or methane generation, and (d) alternate water supply should monitoring Indicate that the containment site has failed. 3. .Th development of grievance and arbitration procedures and the Investi gation of the feasibility of liability Insurance for any claims arising In connection with the public health aspects of the project. 4. Provision for specific funding mechanisms by NYSOEC to assure Imple mentation of long-term contingency plans, operation, maintenance, and monitoring. 5. Redesign of the containment site leachate collection and storage system to improve operations and to avoid clogging and buildup of leachate within the site. 6. Provision for storage of NYSOOT maintenance dredging materials from sites 212, 13, 204 Annex from Washington County only (If removal Is deemed necessary), under the condition that the state bear the Incre mental costs associated with relocation and long-term encapsulation. Water Quality Monitoring 1. Develop a long-term monitoring program to evaluate the Improvement of the recovery rate of the river and fisheries. 2. Develop a long-term monitoring and raintenance program If In-river containment Is Implemented to determine leaching of PCBs back into the river. 3. Develop a downstream public water supply monitoring program for PCBs and heavy metals to be Implemented before, during, and after dredging operations, especially during and shortly after high flows. Contingency plans to provide additional water treatment or alternate water supplies also should be developed. 4. Develop a short-term monitoring program for air quality, water quality, and biota during dredging and disposal operations. S-12 MOWS 009315 CITIZEN INVOLVEMENT It Is also recoamended that If either the full-scale or the reduced-scale project Is undertaken, the CAC and the Settlement Advisory Committee (SAC) be continued at least through the operational phase of the project, and beyond If so desired by the respective committees. The committees Mould serve as a community focal point for the distribution of project Information and data and, at the same time, provide oversight and local and technical liaison between the affected communities and the operational and regulatory agencies, including EPA. The CAC has raised two Issues of public concern which should be considered by New York State. 1. NYSOOT should develop a comprehensive PCB dredge spoil disposal plan for the upper Hudson River, also within the same time frame as this proposed project. 2. NYSOEC should consider providing assurances that neither the pro posed containment site nor the surrounding land acquired by New York State will be used for the future disposal of any hazardous waste generated from either within or outside Washington County. HONS 009316 Chapter 1 2 3 TABLE OF CONTENTS _____________ Title________________________ Executive Summary Table of Contents List of Tables And Figures INTRODUCTION Summary of Public Hearings Hudson Falls Public Hearing Poughkeepsie Public Hearing New York City Public Hearing MODIFICATIONS TO THE OEIS Specific Modifications Air Quality Analysis Summary of Impacts for the Recommended Plan RESPONSES TO COMMENTS CAC Comments Oredglng Operations Containment Site Modifications Project Alternatives Other Comments FEDERAL, STATE, LOCAL, ANO OTHER SOURCES FROM WHICH COMMENTS HAVE BEEN RECEIVED ABBREVIATIONS USED CORRESPONDING ENGLISH ANO METRIC UNITS REFERENCES LIST OF PREPARERS APPENOICES Appendix A - Response to Executive Summary of Draft Envlroneental Impact Statement Appendix B - Cultural Resource Survey for Site 10, Abstract Appendix C - PCB Settlement Agreement Appendix 0 - Federally Listed or Proposed Endangered or Threatened Species In the Hudson River PC8 Reclamation Demonstration Project Appendix E - Concentration and Public Health Significance of Ceslun 137 in the Proposed Containment Facility Pent S-l 1 11 1-1 1-1 1-2 1-3 1-4 2-1 2-1 2-5 2-7 3-1 3-1 3-5 3-14 3-26 3-29 3-33 4-1 5-1 6-1 7-1 8-1 A-l B-l C-l D-l E-l HONS 009317 1 Humber Tibi* S-l Table 2-1 Flgurt 3*1 Tiblc S-2 LIST OF TABLES AND FIGURES Title USEPA Recomnended Program Inpact Sumary of Recomnended Plan Artesian Groundwater Flow NYSOEC Recommended Program Page S-l 2-1 3-17 S-2 11 HONS 009318 k CHAPTER 3 Responses to Comments HONS 009319 CHAPTER 3 RESPONSES TO COMMENTS Comments on the OEIS were received from a variety of government agencies and other interested parties during the OEIS public hearings and comment period. A list of these organizations and Individuals Is given on pages 4-1 and 4-2 of this Supplemental OEIS. Written comments were reviewed, and representative sections of these comments are addressed below. The comments that follow are direct quotations. When two or more comments were received on.similar or related subjects, the one most representative of the others was chosen and is addressed below. The comments addressed are divided into 5 main catagories as follows: e CAC Comments a Dredging Operations a PCB Containment Site __ a Monitoring and Contingency Plans a Alternative Actions a Miscellaneous __ All comments received from the PCB Project CAC have been Included with responses because of the committee's special Involvement In the review process for the proposed dredging project. I. CAC COMMENTS The CAC comments were presented by.George R. Mulvaney, Chairman, at the PCB Project Public Hearing at Poughkeepsie, New York, on June 23, 1981. At the time, the CAC neither endorsed nor condemned the project. The CAC coaaaents. with responses, are presented below. 1-1. Comment: Dec has earmarked funds for the full-scale project and has the responsibility to seek such funding In the future. Response: This was a recommendation in the OEIS. HONS 009320 3-1 1-2. Consent: [We Mould like] Assurances that the scaled-down containment facility will also be able to' accommodate the dredged eaterlal recovered from the full-scale project. Response: There Is adequate area at the proposed containment site for the additional capacity that would be needed. 1-3. Consent: EPA should Include In Its final environmental Impact statement a copy of the legal agreement between the State of New York and General Electric which releases General Electric from respons ibility (above $3,000,000.00) for the Hudson River clean-up. Response: A copy of the settlement agreement between General Electric and New York State Is Included in Appendix C of this Supplemental DEIS. 1-4. Comment: We recommend that EPA/OEC guarantee that Hudson riverbank residents will be contracted at least two weeks before any action Is taken affecting the property of those residents (e.a. cutting or removal of trees, brush; removal of docks, etc.). Response: Contact procedures for river bank residents that My be directly affected are defined In the project operational plans designed by NYSDEC and are included in Appendix A. 1-5. Comment: We recommend that EPA/DEC provide plans to insure the safety of riverbank residents from PCS volatilization during dredging operations adjacent to their property (e.g. shallow cove dredg Ing). Response: Plans to ensure the safety of riverbank residents, as well as residents near the proposed containment site, are described in the project monitoring plan designed by NYSDEC and Included In Appendix A. 1-6. Comment: We recommend that EPA/OEC provide monitoring devices to measure volatilization for the duration of dredging adjacent to the property of riverbank residents. Response: Provisions for measuring PCB volatilization from the river before, during and after dredging are contained in the project monitoring plan prepared by NYSOECand Included in Appendix A. 1-7. Comment: We recommend that EPA/DEC guarantee the safety of residents living In close proximity to hot-spot dredging operations. If air levels of PCBs exceed those recognized as safe, we recommend that residents be housed In safe areas at the expense of New York State for the duration of the dredging adjacent to their property. MONS 009321 3-2 Response: Although excessive PCB volatilization during dredging Is net expected, plans for mitigating such volatilization are contained In the mitigation and contingency plans prepared by NYSKC and Included In Appendix A. - 1-8. Comment: We find It unacceptable that EPA recommends In Its Draft EIS that as an area of `possible savings' (p. B-23), they would leave In place the approximately 12-acre roughing and storage, surge pond and treatment pond dikes after the completion of the dredging project. He recommend that EPA/DEC guarantee that this area will be covered and monitored and treated as a part of Site 10 maintenance within 2 budget years of completion of the project. Response: A plan for closing the roughing and storage area, sewage pond and pond dikes will be made part of the total containment site closure plan and defined in the Toxic Substances Control Act (TSCA) permit. 1-9. Comment: He recommend that EPA/OEC guarantee that Site 10 be monitored and maintained In perpetuity with New York State funds allocated through legislation for this exclusive purpose. Response: The long-term monitoring program designed by NYSOEC and the relevant financial assurances are Included In Appendix A of this final EIS. 1-10. Comnent: He recommend that EPA/DEC conduct a study to find out the feasibility of protecting the dowi-river drinking water supplies with powdered activated carbon and to guarantee these com munities safe drinking water. Response: It Is not projected that any down-river drinking water supplies will become contaminated as a result of dredging activities. However, as an added safety measure, contingency plans to ensure safe drinking water to those communities which derive their water supply from the Hudson River have been prepared by NYSOEC and are included In Appendix A of this Supplemental DEIS. A study solely to determine the feasibility of protecting down river water supplies.with powdered activated carbon Is not part of this project. 1-11. Comment: He recommend that EPA/DEC guarantee that trucking of PCB-laden materials or other contmalnated materials from the river anr surrounding areas take place In specially designed sealed trucks. Response: There are presently no plans In the recommended project to truck any PCB-contaminated materials. If monitoring determines that the remnant deposits are releasing significant aaounts of PCBs 3-3 HONS 009322 ' Into the Hudson Siver, complete or partial removal of the deposits, possibly by trucking, may be recommended In the future. A plan for the safe removal of remnant deposits mould then be designed and Implemented. 1-12. Comment: We recommend that EPA/DEC guarantee that a citizen oversight committee be funded for the duration of the project. Response: NYSOEC will provide a consultant to oversee the dredging and disposal operations. This consultant will ensure that environ mental and health specifications, as well as quality control, are carried out effectively. NYSDEC officials will also be involved-wlth periodic Inspection of all aspects of the project. Citizen oversight of the project will be provided by the PCS Settlement Advisory Committee. A recommendation In the DEIS Is to continue the operation of the CACthroughout the duration of the project and beyond. If they so desire. The issue of funding the CAC beyond the period of the EIS preparation will be con sidered in the award of the final project grant. 3-4 HONS 009323 II. 0RED6IN6 OPERATIONS Comments on the dredging operations were mainly concerned with the follow* ing Issues: e Selection of areas to be dredged; a Dredging procedures; e Losses of PC8s to the water; a Impacts on downstreaa water supplies; a Worker and public health Impacts; and a Long-term Impacts on PCB levels in sediments subject to maintenance dredging. II-l. ' Comment: The proposed budget of $26+ million is only for a partial dredging program. The public has not been notified of a timetable or allocation of funds to complete the project. (Burkhardt, Fort Edward, New York). Response: . The EPA has determined that the reduced-scale project offers potential benefits and will provide for deswnstration of river recovery while not endangering public health. If the final NEPA (National Environmental Policy Act) decision is to implement the project and additional funding has not yet been committed, the reduced-scale project will be initiated. Additional fundswl11 continue tp^be sought by state, federal agencies and environmental organizations. If additional funds become available during the implementation of the reducedscale project, dredging will continue and the containment site will be expanded to its original full-scale design. I1-2. Comment: The proposed Reclamation Plan Involves dredging only the 'hot spots* In the Upper Hudson. It assumes that areas of highest PCS concentration contribute most to the downstreaa load and concludes that they should be dredged first. Yet many hot spot areas are stable sediments and may be scoured under only the severest flood conditions. Some sediments containing rela tively lower concentrations of PCBs appear to scour at a higher rate and could be contributing significantly to the overall PCB downriver flow. The primary method of PCB transport in the water column, whether dissolved or adsorbed to particulates, has not been clarified. To properly assess remedial measures we need more information about the mode of transport. (Natural Resources Defense Council, Inc., New York, New York). Response: As part of the pre-dredging monitoring program, NYSOEC will sample sediments in the upper Hudson River to define hot HONS 009324 3-5 spots, as welt as areas with less than 50 119/g (ppm) PCBs. In terns of location, .extent, PCB concentration, depth of contamination, and PC8 mass. These results will be compared to data collected In previous years to determine which areas have changed significantly. NYSDEC will also assess how susceptible the contaminated areas are to scouring under normal and flood conditions. This pre-dredging sampling is described In Appendix A. In addition, NYSDEC will conduct a study to determine the relative Importance of scouring and desorption in releasing PCBs to the river. This will clarify whether PCBs are prinarlly transported in the water column, adsorbed to particles or dissolved In the water. This program is- talso described in Appendix A, and results will be used to finalize the decision as to exactly which areas will be dredged. II-3. Comment: The reduced program does not provide for restoration of 'espe cially valuable wetlands,* at hot spot 40 and between hot spot 30 and lock 2. The final Environmental Impact Statement should comment on this. The EIS should also Identify precisely which hot spots will be contained and which will be dredged for off-site disposal under a reduced program. The identification of the 20 hot spot areas should not be done during the 45-dpy coamwnt period on the EIS. (Solomon, Congressman, United States House of Representatives, Washington, O.C.) Response: ' No restoration of wetland hot spots will take place under either the full- or reduced-scale plans. NYSDEC wetland biologists have Identified which hot spots contain particularly valuable wetlands (Chapter 3, Section 3B of the DEIS) and the possible preservation of such wetlands will be taken into account when it Is determined which specific hot spots are to be dredged. It Is unlikely that hot spot 40 will be dredged under the reduced-scale project. An extensive sailing program will be Implemented prior to any dredging operations to id entify the locations and PCB concentrations of hot spots and other areas of deposition. It is advantageous to have the saapllng program immediately precede the onset of dredging to minimize the possibility that movement of any hot spots occurs between the time of the sampling and the dredging. In-place containment Is another alternative for dealing with PCB hot spots, particularly wetland hot spots. NYSOEC has Identified two valuable wetland hot spots that are suitable for containment In-place under both the full- and reduced-scale programs. (Appendix A). ____ II-4. Comaent: What effect will hot spot dredging have on wetlands? The possibility that wetland values may preclude dredging of sam hot spots should be thoroughly Investigated, particularly in connection with the full-scale project. (Natural Resources Defense Council, Inc., New York, New York). Response: See comment 11-3 and response. 3-6 HONS 009325 I i I I I - ; II-5. Comment: Response: Please define 'dredging season*: l.e., give aonths, taper*-1 ture range, etc. (Shapot, CAC, Cold Spring, New York). The maximum dredging season during which PCBs could be rant* I from the river is fra May to November. This Is based e typical weather conditions of the region. Freezing of til I river usually occurs In December and forces the barge cae U system to close. Ice conditions can persist into March, am I high flows fra the spring thaw occur through April. Ik remainder of the year should be suitable for dredging act! I vlties, unless a storm temporarily creates unusually hfga flows. <* 11-6. Comment: The dry, low flow season has correct!y| been selected fe commencing dredging operations to reduce high flow drd( plume losses. However, for high flow conditions during c immediately following severe storm runoffs, will dredg operations be curtailed? It may be advisable that high fls cutoff and dredging resumption levels be established to redes piuam losses. Again, such precautions should be establish at this time. (Kim, Director, Bureau of Toxic Substance: New York State Department of Health, Albany, New York; Response: As described In Appendix A, NYSDEC plans to utilize exist! flow control structures In the upper Hudson River as much . possible to moderate flows during dredging operations. high flows occur because of a storm or other factor, dredgf operations will be halted for the duration of the high flam avoid excessive plume losses. II-7. Comment: ' Please explain for reader why PCS concentrations are lowest the moderate flow range. (Shapot, CAC, Cold Spring, York). , Response: NYSDEC data Indicate that PC8 concentrations In the ugp Hudson River tend to be highest during high flows, >owe during intermediate flows, and somewhat higher at low flow Concentrations are highest during high flows because scowrr of sediments Is occurring and PCB-contaminated partlcl from the riverbed are being suspended into the water coho Lesser amounts of PCBs are added to the water colamn desorption from contaminated sediments, a process which fairly constant over all river flows. During low flows. Is thought that PCB concentrations result from desorptiom A the sediments and also from the suspension of contaaima particles due to the operation of barges in shallower wete Flows in the intermediate range are not swift enough suspend contaalnated particles, and contaelnated tillhas are not stirred up by boat traffic because waters are deem 3-7 MONS 009326 11-8. Comment:- The EIS asserts that during the dredging operation 2 to S percent of the PC8s would be lost back Into the water coliam or would not be captured. The basis for that assumption of such a low release Is not clear, not Is there much discussion of the likely negative Impact of those releases. (Solomon, Congress man, United States House of Representatives, Washington, D.C.). Response: Losses of PCBs to the water during dredging are discussed In Chapter 2, Section 3A, and Chapter 4, Section 3A, of the DEIS. Tables 2-10 and 2-11 of the OEIS present the following data on PC8 losses: lo Clmashell with hydraulic puepout Hydraulic dredging and transport. loss Mechanism Missed during dredging Lost In dredging process Lost In return flow Total Loss Missed during dredging Lost In dredging process Lost In return flow Total Loss Estimated PCS loss It) 5 0.8 -4 0.01-0.1 5.8 -9.1 2 0.4 2 0.1 2.5 - 4.1 These data are based on estimates by MPI, and laboratory and . field measurements collected by NYSOEC and COE, as discussed In the DEIS. Since the clamshell dredging Is recommended In the reduced-scale project, the total losses are estimated to be 6 . to 9 percent. However, by utilizing special dredging buckets with seals and shrouds as planned, total losses should be closer to 6 percent. The dredging operation will be monitored closely, and operational/mltlgation plans have been developed to minimize adverse Impacts. These are described In Appendix A. Based on the information presented in the DEIS, it has been concluded that the dredging operation, with the required modifications and safeguards, will not have significant adverse effects, although there may be short-term dls-turbances In the Immediate area of the dredging operation. II-9. Comment: At present the rescoped project reconntends clamshell dredging with hydraulic pumpout. The selection of clamshell over hydraulic Is not adequately substantiated with an analysis of relative cost and effectiveness. This Is especially Important since the hydraulic method Is more effective and does not cost much more than clamshell. (Natural Resources Defense Council, Inc., New York, New York). Response: MPI and NYSOEc'(MPI, 1980c) considered several different types of dredging, transport and unloading systems for use in the Hudson River PCS Project. Each system was evaluated in terms of technical, environmental and economic feasibility for removal of contaminated deposits from the river and disposal in the proposed containment site. HONS 00932 7 3-8 Tha hydraulic dradga offers greater PCS removal efficiency and cutting precision as compared with the clamshell dredge, and therefore has smaller short-term environmental effects. Its use Is limited, however, to hot spots which are less than one mile from the containment site, or two miles with a booster pimp, and to those which have suitable substrate (no large debris or exposed ledgerock). The clamshell would be the most suitable dredge for the remaining hot spots. Oredglng In shallow areas nay require specialized equipment such as a nod . cat. Recycling of the clamshell puapout water reduces the project cost as well as PC8 losses to the river. In general, the cost differential between alternatives Is slight (MPI. 1980c). As described In Appendix A of this SuppleMntal DEIS, modifications will be made to either dredge system to minimize PC8 losses to the river. Under the full-scale project, hydraulic dredging would be most suitable for dredging of hot spots relatively near the proposed containment site, such as the Thompson Island Pool hot spots, but clamshell dredging would be required for the lower pools. . Under the full-scale program, NYSOEC planned to defer final selection of either system until the competitive bidding for the dredging was completed and cost-performance data was available (MPI, 1981). With the reduced-scale program, significantly less funds will ' be available for the second season of dredging of the lower hot spots. If a clamshell system is not used at the Thompson Island Pool, remaining funds may not be adequate for cons truction and amortization of the special equipment that would be required for the lower pools (MPI, 1981). Therefore, clamshell dredging with hydraulic pumpout Is likely to be the most effective system for the reduced-scale project. 11-10. Comment: On the subject of short-term health concerns as raised In the EIS, I believe there should be a better quantification of the "minimal* public health effects of short-term air and water PCS releases during the construction phase of the project (see page 4-19) and nore detail on worker protection measures. (Solomon, Congressman, United States House of Representatives, Washington, D.C.) ' Response: - The predicted levels of PCBs In air and water during the construction phase of the project are not likely to exceed NYSOOH recommended guidelines. These guidelines are con servative levels formulated for the protection of public health. A quantification of minimal public health effects of short term exposure to these low levels of PCBs cannot be made. For details of worker protection measures, see comment 11-15. HONS 009328 3-9 II-U Comment: I Mould like to question the information in the last paragraph In your sunwary on page.A-11, Appendix A concerning huaan exposure and risk assessment associated with the dredging program. If you do not possess the data to quantify the increases In atmospheric, fish and drinking water levels should a flood resuspend contaminated sediments, you cannot possibly assess the danger which the disturbance of contaminated sediments by clamshell dredging poses for residents of this area. I do not see how It Is possible to proceed with a project of this nature until you can be more specific about the Impact of the project on human health. (Mulvaney, Argyle, New York). Response: Based on the projected losses of sediment from the dredging process described in the 0IS (Chapter II, Section 4 and S and Chapter IV, Section 1-4 and 1-5), no significant, adverse Impacts on public health or natural resources are expected in the affected area (also see eoonent II-8). As a precautionary measure, however, monitoring, operational standards and initiative measures to ensure public safety are required as part of the project and are described in Appendix A of this document. 11-12. ' Comeent: The Environmental Impact Statement fails to respond adequately to the effect of the dredging process on drinking water In localities downstrea not using activated carbon filtration systems to purify their drinking water. Not enough Is known about PCB levels In drinking water supplies In those com munlties today and this data should be collected In order to determine If the Installation of carbon filtration systems should be required as part of the demonstration project. (Solomon, Congressman, United States House of Representatives, -Washington, O.C.). Response: It Is not expected that dredging will have a detrimental impact on downstream drinking water supplies. Monitoring of past Hudson River dredging operations and other studies conducted by NYSDEC and confirmed by COE show that the dredge pluae will not extend more than two miles downstream (Chapter 4, Section II3A of the OEIS). Waterford, which Is about 6 miles downstream of hot spot 40 and 30 miles downstream of the Thompson Island Pool, Is the closest direct water supply Intake to potential dredging activities. Waterford uses powdered activated carbon In addition to conventional water treatment methods- Poughkeepsie and Rhlncbeck, which also draw water directly from the Hudson River, also use powdered activated carbon. Stillwater and Schuylervllle utilize wells -adjacent to the river, and Green Island uses infiltration galleries on an island in the river. Flow through the ground provides substantial filtration of raw river water. Some homes along the river use water directly from the Hudson River for watering lawns and gardens. 3-10 HONS 009329 - Although no Increases In PCS levels In utter supplies are likely fra* the dredging operations, both rlverwater and water supplies elll be monitored. Contingency plans. Including use of activated carbon, have been developed by NYSOEC and are described In Appendix A. 11-13. Comment: On page 4-57 the EIS states that If PCB and heavy aetals near water supply Intakes exceed 'safe limits* during the dredging process, additional treatment or alternative supplies will be required. I believe there Is a need for fuller explanation of the action that would be required (and on whom the res ponsibility would fall) under such circumstances and how quickly It could be put In place to protect drinking water supplies If problems were detected. Likewise, It Is not known how many private Individuals are drawing water from the river through privately owned wells located near the river and the EIS does not indicate what protective measure should be taken for them. (Solomon, Congressman, United States House of Representatives, Washington, D.C.). Response: Monitoring and contingency plans to protect water supply have been designed by NYSOEC and are discussed In Appendix A. In addition, an Inventory of private water supplies Is presently being conducted and provisions will be made to provide a safe and adequate source of potable water supply. If necessary. 11-14. Coement: One of the safeguards protecting downstream water supplies Is the halting of dredging operations If the ambient PCB levels exceed 0.5 parts per billion (p. 4-43). No provisions are made, however, for the monitoring and mitigation of other toxic chemicals that have been discharged into the project area from Industrial sources for many years. We would recoaaaend that testing of the sediments be performed to determine the extent of the problem and that appropriate measures then be taken. (Fear, Captain, U.S. Coast Guard Chief of Staff, Third Coast Guard District, Governors Island. New York). Response: Levels of heavy metals. In addition to PCBs, will be measured before, during and after the dredging and disposal operations as part of NYSOEC's sampling prograa for the project. The NYSOEC sampling program is described In Appendix A. Heavy metals that will be measured Include: arsenic, cadmium, chromium, copper, lead, mercury, nlckle, silver and zinc (Tofflenlre, NYSOEC, July 30, 1981). Levels of heavy metals will be amasured In: the Hudson River doMistream of dredging operations, the water flowing from the containment site to the Hudson River as dredge spoils undergo dewatering; the groundwater at monitoring wells around the containment site; and the wells of residents near the site. Contingency plans 3-11 MONS 009330 to protect drinking Water supplies, as described In Appendix A, apply to heavy Metals as wel.l as PCSs. 11-15. Comment: We recommend that respirators designed for removal of organic vapors be provided for all workers on dredges and at the containment site. They should be Instructed in use of the respirators, informed of existing OSHA standards and NIOSH and DOH guidelines concerning PCBs, and Informed of air sapling results as soon as they are available. Each worker should be free to determine whether he or she wishes to use respiratory protection at PCB concentrations below the OSHA standard. (Kim, Director, Bureau of Toxic Substances, New York State Department of Health, Albany, New York). Response: Use of respirators was a recommendation by EPA in the DEIS. 11-16. CoMMent: Sentence 6 on page S-10 which states that 'removal and in river containment of PCBs from the upper Hudson River Is not expected to significantly reduce the PCB sediment concen trations in the New York Harbor* Is misleading as worded. The draft states that the proposed reduced-scale project would reduce the PCB flow into the estuary to 61.200 kg, compared to the 'no action-no routine maintenance dredging* alternative flow of 112,000 kg. -(Hammon, Vice Chairman, Save. Our Port, New York, New York). Response: As discussed in the DEIS, it is likely that much of the PCBs that flow over the Troy Dam into the Hudson River estuary settle in the Albany Turning Basin/ Harbor, which is routinely dredged, and other deposltlonal areas along the length of the estuary. In addition, there will be volatilization of PCBs from the estuary as well as the upper Hudson River, further reducing the amount of PCBs reaching New York Harbor. As discussed in the OEIS. It is estimated that only about 30 percent of the PCBs that are transported over the Troy Oam reach New York Harbor. Therefore, the reduced scale project, when compared to the no-action alternative with navigational dredging, will reduce the amount of PCBs entering New York Harbor by approximately 8,000 kg (17,600 lbs) between 1981 to 2013. It is expected that an equal or greater amount of PCBs will be removed for the harbor by routine maintenance dredging. In addition, ft has also been estimated by Bopp (1979) that a substantial amount of the PCBs (25 to 30 percent) in the New York Harbor originated from discharges along the lower Hudson River. PCBs were used in numerous manufacturing processes and have been discharged from municipal sewage and Industrial outfalls, dump sites and other sources. Thus, a significant reduction in PCB concentrations in New York Harbor sediments cannot be quantitively projected on a harborwide, average flow basis. 3-12 MGNS 009331 It Is Important to consider, however, that the calculations of PCS transport to New York Harbor presented In the DEIS assumed that river flows would be constant and sediments would be distributed harborwide. Actually, substantial loadings of PCBs to the harbor may occur for short periods during flood events on the river. Instead of being evenly distributed. It Is likely that local deposition of PCBs will occur at certain harbor areas. Heavy, short-term loadings and localized deposition of PCBs In the harbor could be critical to the continuation of maintenance dredging In the harbor and ocean disposal of dredge spoils, especially because some harbor sediments already have PCB levels of 3 to 4 ug/g (ppm). (PC8 levels of above 4 ug/g (ppm) In dredge spoils could preclude ocean disposal of the spoils, depending on the outcome of COE toxicity testing.) Although It Is not quanti fiable, the full- and reduced-scale dredging alternatives may have a significant beneficial Impact on areas of high de position within New York Harbor or during periods of flood conditions, compared to the no-action alternative. 11-17. Coaments: ' . Insufficient emphasis has been placed on the effect of no action on dredging the Hudson channel. Last year's operation In the Albany Turning Basin produced PCB levels approaching the 50 ppm level. Obviously, failure to remove the hot spot would risk future dredging of this vital component to the Albany Port, or at least greatly Increase the cost since a specially designed and contained disposal site would be needed. The same problems would be encountered in maintaining the barge cana) system. Just this past spring, an emergency dredging of a PCB hot spot in the Champlain section of the canal produced a number of problems. Future occuranccs would threaten the state DOT'S ability to maintain a navigable systen. All of these very real threats are downplayed in the EIS In favor of the potential, and apparently unlikely, threat to the habor. (Cohn, Chief, Planning Division, North Atlantic Division, COE, New York, New York). Response: The risks to the continuation of maintenance dredging in the upper Hudson River because of excessive PCB-contamination of sediamnts were recognized in the DEIS. A finding of the DEIS (page 5-9 of the Executive Summary) war that removal of PCBs from the upper Hudson River would reduce the risk that navi gable waterways In both the upper and lower Hudson River would be closed because of the Inability of New York State Depart ment of Transportation (NYSDOT) to provide adequate upland disposal of contaminated sediments. In Chapter 2 of the OEIS (page 2-3), It was recognized that critical navigational areas In the upper Hudson River, such as the Albany Turning Basin, already have high PCB levels. Under the no-action 3-13 HONS 009332 alternative, PCB levels at Albany can be expected to Increase over the next 30 years. Although the problems may be more Immediate In the upper Hudson'RIver, It was also recognized In the DEIS that PCB contamination threatens the continuation of ocean dumping of dredge spoils and of maintenance dredging in New York Harbor. A substantial amount of the PCBs in New York Harbor sediments originates from the upper Hudson River. III. CONTAINMENT SITE Comments about the proposed containment site generally concerned the following subjects: III-l. e Design and operation of the containment facility: Geologic stability of the site; Short- and long-term monitoring: e Threats to public health; e Threats to agriculture; and a Other possible contaminants In the site. Comment: I fee1 EPA has taken a reasonable position in viewing the containment site as a permanent depository of the dredge spoils, since the technology for ultimate destruction of the spoils does not appear to be available In the near future. However, If the spoils are to be stored at the site 1ndefinitely, I recommend that the EIS contain an analysis of the anticipated persistence of PCBs in the site. A similar analysis of the persistence of other toxic substances In the spoils would also be helpful. Such analyses would give an Indication as to how long the site would contain hazardous wastes. This estimate, in turn, would help in determining how long the site would require monitoring, and also what may be the likelihood of groundwater contamination in the long term (although the Richard estimates on page 4-61 suggest this would not be a problem until the extremely distant future). (Uhyatt, Scenic Hudson, Inc. and the Hudson River Fishermen's Association) Response: Because PCBs are extremely stable in the environment and heavy metals do not degrade, these contaminants will persist Indefi nitely. Although the long-term monitoring program for the containment site is being defined as a 30-year program, monitoring and maintenance of the site will continue well beyond the 30-year period. Because the site Is designed for Indefinite storage. It Is not expected that the groundwater will ever become contaminated to an extent that would preclude Its use as a source of drinking water supply. 111-2. Comment: The leachate drainage system [at the containment facility] appears to have a reasonably projected probability of clogg ing, which can lead to capping rupture. (Coffin, Pough keepsie. New York). 3-14 HONS 009333 Response: Potential clogging problems with the leachate collection system have been addressed by NYSOEC, and a discussion Is Included In Appendix A. The collection system has been designed so as to prevent or minimize clogging. If the dredged material contains a large proportion of fine grained particles, clogging nay eventually occur In some portions of the leachate collection system. However, a key point Is that the leachate collection system offers a much easier pathway out of the containment area than percolation through the clay bottom. If there are sufficient fine-grained material to clog the collection system, they will also effectively seal the Idnterfacle between the dredged material and the clay bottom, thus preventing any leachate escape at all. In that event It would be necessary to remove leachate throuth vertical wells located on the site. There fore, rupture of the cap would not occur. III-3. Comment: With a limited capability In the field of hydrauallc engineer ing, one must assuae observable conditions. In my experience, liquids will percolate downward In the spots of highest permeability. Thus, It follows that generally the leachate will migrate downward at the spots offering the least resi stance, and further, the less permeable (more resistant) soils will provide somewhat of a 'table" to collect additional liquids to seep down the softer spots. ' Thus one must conclude that liquid leachate, with whatever contaminants are dissolved In it, would sink through the underside in about 5 to 6 years. In most land areas that I am acquainted with, once seepage (drainage) begins, the process Is usually self-expanding. Hence, a presumption of ground water contamination Is a necessity from the data supplied (Coffin, Poughkeepsie, New York). Response: It Is Incorrect to use permeability values to calculate the amount of time It will take for Interstitial waters to pass through the clay liner from the containment site, as done by Mr. Coffin. The permeability values given in the DEIS (page 4-61) are rates of lateral movement that take place when a given material contains water with a water table slope of 1 on 1 (45 degrees). Any calculations of flow rates must take into account the water table slope, projected to be approxi mately 5 degrees for the completed containment site (Sanders, PCB Settlement Advisory Committee, June 26, 1981). According to Darcy's Law, the rate at which water flows through a permeable substance Is basically proportional to the per meability of the medlimi and the difference in height of the water table (Oewlest, 1965). 8ased on a projected finished slope of 5 degrees and the parmeablllty values determined by field and laboratory 1nvestlgations of the proposed site. It has been estimated that 3-15 HONS 009334 It would take 600 years for leachate from the containment site to travel a distance of 60 m (200 ft) to the property line of the site. It would take over 1000 years for water within the containment facility to seep through the Inside face of the dike (page 4-61 of the DEIS). The movement of PC8s and heavy metals would be further slowed by adsorption onto clay par ticles. Adsorption onto clay would reduce the movement of these contaminants to 1/100 to 1/10,000 of the water flow rate (page 4-61 of the OEIS). It Is unlikely that downward percolation of leachate from the containment structure will take place because the groundwater beneath the clay Is under a slight artesian (upward) pressure. In other words, water has a slight tendency to flow upward through the clay Instead of peculating downward as shown In Figure 3-1. ERA regulations (40 CFR 761, Feb. 17, 1978) require an In place soil thickness of 1.2 m (4 ft) or a compacted soil thickness of 0.9 m (3 ft) with a-permeabllity no greater than 3.9 x 10'" In/sec (1.0 x 10"' cm/sec) for PCS disposal sites. New York State regulations (6 NYCRR 360, May 17, 1977) require a clay seal having a jjermeabllIty of not greater than 3.9 x 1- In/sec (1 x 10*3 cm/sec). Laboratory tests on clays from the proposed site yielded permeabilities on the orir of 4 x 10" and- 4 x 10 * tn/sec (1 x 10"' and 1 x 10'" cm/sec) In both the vertical and horizontal directions. Field permeability tests are largely controlled by horizontal permeability, and field permeabilities were generally found to be higher than permeabilities measured in the lab because of more pervious horizontal seams. Clays at the site will be compacted for construction of liner walls, eliminating the effect of horizontal seams. This will result In material with a permeability of less than 3.9 x 10' in/sec (1 x 10*' cm/sec) (MPI, 1980a). Clays at the base of the containment site will also be disc-harrowed and recompacted to eliminate any Imperfections in the clay layers. The compacted clay liner plus the natural clur base with a vertical permeability of less than 3.9 x 10' In/sec (1 x 10*' cm/sec) will provide an impermeable base for the containment area that meets both state and federal regulations concerning PCS disposal sites (MPI. 1980a). Satisfactory geologic conditions were major factors considered by NYSOEC In selection of a possible PCB disposal site. The results of the geotechnical Investigation of subsurface conditions of the site conducted by Mueser-Rutledge-Johnson and Oeslmore, Consulting Engineers, for NYSOEC's consultant, Malcolm Plrnle, Inc., are given In PCB Hot Spot Dredqlno Pro<iram^ Upper Hudson River. Containment Site Investigations 3-16 MOMS 009335 RAIN NFITRAnON RAIN INFILTRATION HONS 009336 FIGURE 3-1 ARTESIAN GROUNDWATER FLOW III-4. Comment: We find this Impact report having conflicting Ideas In It. It appears that a lot of time and thought has been given to mater quality and protection In areas outside the containment site. Then you find a statement such as. "In one boring that penet rated the bedrock, artesian conditions were encountered, but the full height was not measured", (page 3-15). It Is not (page 3-16) that Hew York State regulatory bodies would have to provide a waiver of their own laws governing water tables being less than 10 feet from the botton of the containment facility as being a secure landfill. (MeMurray, President, Wanren-Washlngton County Farm Bureau). Response: i It Is highly unlikely that any downward percolation will take place because the groundwater beneath the clay is under a slight (but as yet not determined) amount of artesian (l.e.. upward-directed) pressure. This artesian pressure will, of course, be determined In any future research at Site 10. It could not be determined previously, because the owner closed the site after allowing some preliminary work to be carried out. II1-5. Comment: Land-use planning maps developed for this county [Washington County] ... clearly state that this proposed site Is not suitable for erection of any structure larger than a onefamily home because the shale underlayment will not readily accept the weight of a larger structure. (Saunders and Saunders, Greenwich, New York). Response: The land use planning maps show generalized land use suitabi lities. Preparation of the maps does not Involve specific Investigations of geological conditions at particular sites. , Detailed geotechnical investigations of the proposed contain ment area were performed to assess the site's suitability for long-term storage of PC8-contam1nated dredge spoils (MPI, 1980a). A stability analysis was also performed to determine If the site has sufficient shear strength to withstand long term static loading as well as earthquake stress (see comment no. III-6). These investigations confirmed that geological conditions at the site are suitable for long-term containment of the dredge spoils. The shale beneath the proposed containment cells Is covered by 9 to 23 m (30 to 7S ft) of clay. This clay and not the shale Is the primary load-bearing strata. In addition, there are no cavities within the clay or underlying shale which would permit major shifts In substrata beneath the site. There is not a major fault or underground stream channel below the site, but a depression In the bedrock which Is completely filled with clay and other fine-grained material which pre vents water movement (Thomas, MPI). 3-18 MONS 009337 111-6. Comment: The EPA Itself, In Its EIS admits that seismic events In the area have been "moderately common" and that the locality Is listed In zone 2, a moderate damage seismic risk area. They go on to say that, "there is approximately a ten percent chance that the bedrock units In the area will undergo hori zontal acceleration (shaking) that exceeds nine percent of the force of gravity at least once in a 50-year period." (Hague. Member of Assembly, 110th District, Albany, New York). Response: A stability analysis for the proposed contalnaent site was performed by Mueser-Rutledge-Johnson and DeSimone, Consulting Engineers. The analysis was based on a geotechnical exami nation of the site, and results are presented In Appendix B of PCB Hot Spot Dredging Program Containment Site. Design Report (MPI, ldadb). The conclusion of this analysis was that the site has sufficient shear strength to withstand an earthquake of Intensity VII on the modified Mercalli Scale, with a substantial margin of safety. The modified Mercalli Scale Is used as a measure of the ground-shaking effects of an earth quake. There are 12 levels of Intensity, with XII represent ing the most Intense level. An Intensity VII earthquake Is considered severe and would have accelerations of as much as 10 percent of the mass of the mobilized soil. In general, the stability analysis concluded that there are adequate factors of safety for the containment site to withstand potential earthquake loadings. 1II-7. Camaent: Another question Is the monitoring of groundwater. Page 4-67 gives a detailed account of how the monitoring wells shall be constructed, using sand around, and 2 feet above the top of, the screen. Now, using the Information that PCB particles will be clinging to an organic object and information found on page 2-7 of the Draft Environmental Quality Review that "conventional sand filters remove some 60 to 90S of PCB," and that a PCB test Is not 100X accurate, how Is this test well going to monitor the water? (McMurray, President, Warren Washington County Farm Bureau). Response: A property of PCBs Is that they readily adhere to particles, especially fine-grained particles, such as clays, or organic particles. That Is why they accumulated In sediment of the Hudson River In the first place. The groundwater monitoring wells around the containment site will be placed in soils that are naturally comprised of fine grain particles. This type of soil Is highly impermeable and provides a high degree of affinity for PCBs. The monitoring wells will be back-filled with clean, well-sorted sand and grout that has a relatively high permeability and low affinity for PCBs, as compared to the natural soils. The sand and grout will permit water to flow relatively easily from the natural clays to the monitor- 3-19 HONS 009338 Ing wells. If PCBs were to flow through the natural clays, they would move Into the wells relatively easily. The sand and grout layer around the well will not be thick enough to provide significant removal of PCBs, If they were to penetrate the natural soils, and PCBs would be detected In the monitor ing wells. This question points out an Important fact: that PC8s, as well as heavy metals such as lead, zinc and cadmium, are highly Insoluable In water and readily adhere to soil particles. PCBs are naturally scrubbed out of water as It passes through the soil, especially fine-grained soil. This Is a major reason why PCB-contamlnated spoils can be effectively retained In the containment site without danger of groundwater con tamination. III-8. Comment: There Is not now one single air or water monitor at that site [New Moreau site]. There will be no more care taken at the proposed site 10 ... (Saunders and Saunders, Greenwich, New York). Response: The New Moreau Site was constructed by NYSOEC and NYSOOT to encapsulate remnant deposit material and dredge spoils con taminated with PCBs. Extensive air, groundwater and leachate monitoring was conducted as disposal operations took place and after the site was closed. No significant levels of PCBs were found, and the initial findings Indicated that It was not necessary to continue monitoring as extensively. Groundwater Is still monitored at test wells around the site. Inspection and maintenance of the cap Is performed twice a year. Al though the site Is onlyseveral years old. It has served as an effective model encapsulation site. As described In Appendix A, the proposed containment facility at site 10 would be throughly monitored during the disposal operations and Indefinitely after the facility is closed. II1-9. Comment: The Environmental Protection Agency should not approve a plan which would discharge dangerous levels of PCBs Into the air (Solomon, Congressman, United States House of Representatives, Washington, O.C.) Response: EPA does not Intend to approve any plan which would endanger public health. Analysis performed during the preparation of the OEIS (Chapter 2, Section II of this supplemental OEIS has determined that, under worst case contaminated sediment disposal and meteorological conditions, ambient air concen trations of PC8s may approach the NYSOOH 24-hour average guideline of 1 ug/cu m at the nearest receptor. To preclude even the possibility of a threat to public health, EPA has 3-20 HONS 009339 conditioned final approval of the project on the development of satisfactory monitoring and mitigation plans, not only for air but also for surface waters, groundwater and crops. Mitigation plans for disposal and long-term operation of the containment facility are summarized in Chapter 4 (Section 40) of the DEIS. Contingency and monitoring plans, developed by NYSDEC and approved by EPA, are discussed In detail In Appen dix A of this document. III-IO. Comment: Firstly, If the fanes and residences In the proposed area -,(beceme uninhabitable, these properties and businesses should be purchased outright for present (before dumpslte location) . value plus yearly Inflation Increments. Secondly, If the land and residences continue to be productive and livable, the owner be compensated by one or any combi nation of the following methods: As In the case of long term capital gains realized from the sale of real property or businesses, that In addition to the present allowable 60 percent exclusion of said gain from taxable Income, these affected residents be able to exclude a further percentage from taxable Income, l.e. an 80 percent exclusion as versus a 60 percent exclusion of the capital gain. Further, that some form similar to an Investment tax credit be Implemented whereby the affected parties would be able to take a portion of the lost value of the property or business as an Income tax credit over a period of several years against Income, or perhaps some form of casualty loss due to the devaluation caused by locating of duspsltes or plants which would render the adjacent properties less valuable. Properties eligible for such consideration would have to be appraised prior to Implementation of this project. (Scelzl, Fort Edward, New York). Response: This Issue and the programs developed to protect the community Immediately surrounding the containment site from severe economic loss are discussed In the section on financial assurances In Appendix A. III-ll. Comment: It Is disconcerting that the potential value of the fishing Industry Is carefully calculated and receives repeated dis cussion, while the agricultural Industry, by comparison, is discussed quite briefly. The value of agricultural production within a few miles of the site Is many times that of the fishing Industry, but the EIS certainly does not indicate that. ---- Now It apparently has been decided that farming may not continue within approximately one third of a mile from the containment site for the duration of the dredging and contain ment operations. 3-21 MOMS 009340 Should the action alternative be chosen, every measure must be taken to ensure that adverse effects on agriculture are prevented. It is the Farm Bureau's responsibility to carry this out. (Jack Hughes, Associate Public Affairs Olrector, New York Farm Bureau, 61enmont, New York). Response: Although the actual value of agricultural production within a few miles of the proposed containment site was not speci fically discussed, the potential Impact on the surrounding agricultural resources was carefully considered in the 06IS. EPA recognizes that the agricultural interests surrounding the proposed containment site need to be protected. EPA has recommended a number of mechanisms, including financial assurances, to protect the farming industry from any loss of agricultural production. As part of the project approval, EPA has required NYSOEC to fully develop assurances and protective mechanisms and to submit them for public comment. Consistent with this approval, EPA has published these NYSOEC project modifications as Appendix A of this Supplemental DEIS. III-1Z. Consent: This sentence [In the OEIS] states "the majority of soils fall [at the proposed containment site] within agricultural suit ability Classes III and IV*. These classes should be defined. Is "Land Capability Class* intended? Based on the soils In the area, the statement that 'prime agricultural soils (prime farmlands) are not present* is correct. The Kingsbury silty clay and Vergennes clay loam, however, are considered Farmland of Statewide Importance. (Dodd, State Conservationist, Soil Conservation Service, United States Department of Agriculture, Syracuse, New York). Response: The soil classes referred to In the DEIS are Land Capability Classes. Classes III and IV are defined by the Soil Con servation Service (USOA, 1975) as follows: Class III soils have severe limitations that reduce the choice of plants, require special conservation practices, or both. a Class IV soils have severe limitations that reduce the choice of plants, require very careful management, or both. Farmland of statewide Importance Is defined as follows: a Additional farmland of statewide Importance--This is land. In addition to prime and unique farmlands, that Is of statewide Importance for the production of food, feed, fiber, forage, and oilseed crops. Criteria for defining and delineating this land are to be determined by the appropriate State agency or agencies. Gener ally, additional farmlands of statewide Importance Include those that are nearly prime farmland and 3-22 HONS 009341 that economically produce high yields of crops when treated and managed according to acceptable farming methods. Some may produce as high a yield a prime farmlands If conditions are favorable. In some States, additional farmlands of statewide Importance may Include tracts of land that have been designated for agriculture by State law. 111*13. Comment: We find It very disturbing to talk about distances of 700 meters minimum with state agencies, when on page 4-63, EPA says the minimum distance should be 2,000 meters, over one mile. (McMurray, President, Warren - Washington County Farm Bureau). Responses: The recommendation in the DEIS to monitor vegetation within 2000 m <6500 ft) of-the site was based on a conservative estimate derived from worse case data collected at the Caputo PCB dump site. More recent studies Involving uptake of PC8$ by plants by (hr. E.H. Buckley of the Boyce-Thompson Institute, Ithaca, New York (under contract by NYSDEC) Indicates that monitoring of agricultural crops Is necessary only up to 200 m (650 ft) from the site. This Is also considered a worse case estimate and will be utilized unless observed data Indicate that additional monitoring needs to be performed. II1-14. Consent: It Is known that PCB can be taken up by plants. The duration and the role In the plant-animal food cycle Is not fully understood. Such facts are vital In understanding the Impact of the proposed program on the dairy farming Industry In the area (Burkhardt, Fort Edward, New York) Response: Studies carried out by Or. E.H. Buckley of the Boyce-Thompson Institute, Ithaca, New York, have documented the rate and degree of uptake of PCBs by various agricultural crops. Including com, alfalfa, red clover and timothy (Sections 4B and 40 of Chapter 3 and Section 4 of Chapter 4 of the OEIS). Dr. Buckley Is presently continuing research on PCB uptake by forage crops and other plants. NYSOEC's appended submittal describes further research, monitoring and contingency plans to be carried out during and after disposal operations to ensure protection of agricultural crops used in the dairy industry. 111-15. Comment: The State of New York should provide legal guarantees to compensate landowners In the region for any loss in property value due to the location of the landfill and for any loss which occurs as a result of transporting the PCB material. (SoIoann, Congressman, United States House of Representatives, Washington, D.C.). 3-23 HONS 009342 Response: Financial assurances to compensate landowners for any losses which may result from the proposed project are discussed In Appendix A. III>16. Comment: Due to the nature of cesium affinity, my estimated value for reeccumulated radionuclides may be off by a factor of 2. But under more expert consideration that matter nay be refined. The question raised therefore, 1$, will the reaccuaulation of low-level radioactive waste that nay occur, make this a low-level radioactive waste site? Do the permits Involved, cover the handling of this type of material? (Coffin, Poughkeepsie, New York). Response: The cesium that will be associated with PC8-contae1nated dredge spoils In the proposed containment site will be found at extremely low concentrations and will not have any public health significance. The radioactive cesltn 137 present in sediments of the Hudson River originated from fallout from atmospheric testing of nuclear devices. The deposition of trace Mounts of cesium 137 approximately coincided with the discharges and deposition of PCBs In the Hudson River. Ceslua 137 that entered the sediments with PC8s also was deposited throughout the land surface of the region and most of the world. Because cesltat has a half life of approxi mately 30 years, most of the cesium is still present in various sedimentary environments as well as terrestrial and marine ecosystems. Because deposition of cesium 137 coincided with deposition of PCBs, cesium can be used as a tracer"for PCBs. Levels of ceslua can provide an Indication of the levels of PCB present In sediments (Bopp and others, 1981). The test for ceslua Is much easier and faster than that for PCBs, so that the cesium -PCB relationship may be useful In the various PCB monitoring prograais planned by NYSOEC for the dredging project. Because of the association of ceslua 137 with PCBs, trace Mounts of ceslua 137 will be present in sediments placed In the containment site. The ceslua will not have public health significance because It will be present In extreaely low concentrations. The cesium will not be differentially leached from the site because cesium, like PCBs, has an affinity for fine-grained particles. This affinity Is why the ceslua adhered to the Hudson River sediments originally. The radioactive materials that will be present In the containment site will have no public health significance because: a They will be present at extremely low levels; 3-24 HONS 009343  They will be highly dispersed in the dredge spoils; and Their radioactive decay product will be largely ab sorbed by the clay cap on the site. An estimate of the amount of radiation that can be expected at the site is contained in Appendix E. 111-17. Consent: These compounds [dioxins and dlbenzofurans] seem to be frequently associated with the presence of large amounts of PCB material. They do appear to have been noted with acti vities, including burn-off of unsecured landfills; e.g. Fort Hiller Oump, also the State Office Building at Binghampton, New York. This association raises major questions wnich have not been addressed in literature I have reviewed. Are dioxins and dlbenzofurans products produced by half-life decay? (Coffin, Poughkeepsie, NY). Response: Trace amounts of polyhalogenated dlbenzofurans (PCOFs), an extremely toxic contaminant, have been found to be associated with PCBs. PCOFs can be present in PC8s as a trace con taminant which originated from the PCB manufacturing process. Trace amounts of PCOFs can also form from incomplete com bustion of PCBs. PCOFs have been found at PCB landfills exposed to burnoff, in the vicinity of burned transformers or capacitors containing PCBs, in heat exchange systems using PCBs, and in fly ash and flue gases of Incinerators. (Mappe, 1979; Appendix A, page A-l of the DEIS). Dioxins are not usually considered to be associated with PCBs (Rappe, 1979). Although they have been found as trace contaminants in PCBs (Appendix A, page A-10 of the DEIS), they are not likely breakdown products of PCBs. Traces of PCOFs have been found In the Hudson River, but it is not known if they originated as contaminants from the PCB manufacturing process or if they formed from combustion of PCBs, such as at a dumpsite. (Tofflemire, NYSOEC, July 30, 1981). There is no evidence to Indicate that PCOFs could form from the natural breakdown of PCBs. The formation of PCOFs from PCBs is a high-temperature process. Significant chemical or biological conversion of PCBs to PCOFs under normal environ mental conditions is unlikely because PCBs are very stable in the environment and because the chemical structure of PCOFs indicates that the substance is not a likely natural break down product. 3-2S HONS 009344 III-18. Comment: We also urge that the New York State Department of Environ mental Conservaton, with the support of the Environmental Protection Agency, assure that the containment site be confined to PCS disposal, and not be used for other forms of wastes which could consume Its capacity for the full-scale project. (Hanmon, Vice Chairman, Save Our Port, New York, New York) " Response: The propsoed containment site has been chosen, planned and designed exclusively for the disposal of PCS-contaelnated sediments from the upper Hudson River region. The terms of a bill passed by the New York State Assembly and Senate In June state that only PC8s dredged from the Hudson River would be burled at the containment facility In Washington County. This bill must also be signed Into law by the Governor, and it will effectively limit use of the containment site for disposal of Hudson River PCBs. IV. MODIFICATIONS This section contains comments on the overall operational standards, procedures and monitoring for the proposed PCS project. These comments pertain to all aspects of the project. Including dredging, disposal and long-term monitor ing. The main categories of comments covered In this section are: IV-X. a Provisions for public comment on modifications; a Project surveillance; and a Long-term monitoring. Comment: New York Farm Bureau Is dissatisfied with the provision for public comment on the modifications. Apparently the public review and coaanent period for the modifications will be the time between the public hearings and the final comment date for the final EIS. This Is Inadequate because the only real opportunity for altering the modifications must be within a period of time before Issuance of the final EIS In order that any changes may be Included In It. The value of commenting on the final EIS Is questionable as It Is unlikely the final EIS would be changed. (Hughes, Associate Public Affairs Director, New York Farm Bureau, Glenmont, New York). Response: The project modifications, monitoring program and contingency plans were developed by NYSOEC In response to EPA's recom mendations In the DEIS. These reconaendations by EPA were based on public consent and Interaction with other govern mental agencies and environmental groups. As a response to public comment, these monitoring and contingency plans have been Incorporated into this Supplemental EIS as Appendix 3-26 HONS 009345 1V-2. IV-3. . A. There will be a 45-day public review and comment period. Additional comments will be taken into account in the final EIS. Coanent: [n its development of operational standards and procedures, OEC should have a team of experts overseeing the operation at all times and retain oversight control. Monitoring of the operation should be extremely sensitive to increases of PCB contamination or air, water, plants and aquatic animal tife. Strong citizen oversight of the dredging operation must be provided for either through the PCB Settlement Advisory Committee or a separate group or both (Mylod, Executive Director, Hudson River Sloop Clearwater, Inc., Poughkeepsie. New York). Response: NYSUEC will provide a consultant to oversee the dredging and disposal operations. This consultant will ensure that environmental and health specifications, as well as quality control, are carried out effectively. NYSDEC officials will also be involved with periodic inspection of all aspects of monitoring during operations. The monitoring program is described in Appendix A. Citizen oversight of dredging and disposal operations will be provided by the PCB Settlement Advisory Commltee (SAC) and possibly representatives of the Citizens Advisory Committee (CAC). The DEIS recommended that CAC and SAC consider undertaking an oversight role for the duration of the project, if it receives final approval. A decision on the role of the CAC and its interface with the SAC will be determined from the recommendation contained in the CAC report and will be made part of the NEPA Record of Decision. Comment: Although we are assured that the project, if carried out as intended, will not threaten public health, we nonetheless consider it necessary that OEC consider a range of spe cialized interests when devising mitigation measures, for down-river drinking water users, alternative supplies or emergency treatment assistance should be investigated. Par commercial, sports and subsistence fishermen, notification procedures and financial or other compensation should be investigated. For residents in the immediate dredging or landfill area, temporary relocation procedures should be investigated in the event that volatilization rates exceed the State 00H [Department of Health] reconmended limits. For area dairy farmers, compensation or other measures should oe investigated in case contaminants impair the marketability of their products. (Uhyatt, Scenic Hudson, Inc. and the Hudson River Fishermen's Association). Response: The monitoring and contingency program developed by NYSDEC contains provisions for all these interests. The program is described in Appendix A. 3-27 HONS 0093N6 IV-4. Comment: I object to the last paragraph on page 6-10 eliminating long-term monitoring from eligible funding. While I agree that the available funds are probably not sufficient for the dredging and long-term monitoring, and that the monitoring should be funded If at all possible from other sources, I feel that the limitation set forth here Is not In eonfonaence with the legislation authorizing the project. This legi slation clearly sets up a demonstration project to determine the feasibility of Indefinite storage of hazardous waste, and to ascertain the rate of recovery of a contaminated waterway from which the waste has been removed. Long-term monitoring Is an essential part of the authorized project. Further, I consider long-term monitoring a priority, both to ascertain the effectiveness of the project, as well as to safeguard the health of people in the project area and downstream. (Whyatt, Scenic Hudson, Inc. and the Hudson River Fishermen's Association) Response: If federal monies were to be used for long-term monitoring (for up to a minimum of 30 years), there would be Insuf ficient funds to undertake dredging. EPA grant funds will be used to monitor the site and the river for a five-year period. As with any 201 Construction. Grants project, once the facility has been completed (In this case, the contain ment facility). It then becomes the responsibility of the grantee, NYSOEC, to fund the long-term operation and main tenance of the facility, including monitoring. NYSOEC has committed Itself to such a long-term monitoring effort to ascertain the effectiveness of the project and to protect public health and resources. The monitoring progran designed by NYSOEC Is described In Appendix A of this document. 3-C8 HONS 009347 V. PROJECT ALTERNATIVES This section contains consents concerning possible alternatives to the PCB dredging and containment project. Alternatives that mere discussed In the comments were: a No-action; e Control of rlverflows; t PC8 recovery with activated carbon; and e Detoxification of PCB-contaalnated dredge spoils. These alternatives were discussed In the DEIS, but they were found to be unacceptable because of public health, technological or economic considerations. V-l. Comment: Proponents claim also that the rate of recovery of the river will be greater with the action alternative. According to the EIS the supply of PCBs above Troy will be exhausted only five years sooner with the action alternative versus the no-action alternative with routine channel dredging. A reasonable question Is whether It Is fiscally responsible to spend more than $26.7 million to dredge only 30 percent of the PCBs out of the river for a recovery period that is nearly as long as with the no-action alternative. (Hughes, Associate Public Affairs Director, New York Farm Bureau, Clermont, New York.) Response: Based on estimates presented In the DEIS (Chapter 2), the supply of PCBs will be largely exhausted In the upper Hudson River by the year 2013 under the no-action alternative, if routine maintenance dredging continues. If routine main tenance dredging Is halted, PCBs will not be exhausted until at least 2028. Under the reduced-scale project, the supply will be exhausted by 2008. Although the time difference for exhaustion of PCBs between no-action with maintenance dredg ing and the reduced-scale project is only S years, no-action will have greater adverse impacts. Public exposure to PCBs will be greater because dredge spoil sites from maintenance dredging will have high levels of PCBs. Volatilization of PCBs will be greater, and contamination of fish will persist longer. A much greater amount of PCBs will enter the lower Hudson River and estuary with no-action. If maintenance dredging Is halted because of difficulties finding adequate disposal sites for contaminated sediments (see comment V-2), PCBs will not be removed from the river as quickly, and an additional 20 years will be required for the supply of 3-29 HONS 009348 V-2. V-3. PCBs to be exhausted under no-action. Aldready sediments In areas that nust be regularly dredged, such as the Albany Turning Basin, have levels of PCBs that could preclude usual spoil disposal practices. The reduced-scale project will remove an estimated 30 to 35 percent of the total PCBs now present In the river, while the full-scale project would remove an estimated 44 to 49 percent (Chapter 2, Sections 4 and 5 of the DEIS). With either project, a substantial amount of the contaalnant would be effectively removed from the river and confined, making It unavailable for further dispersion through the environment by volatilization, transport to the estuary, uncontrolled disposal of dredge spoils from maintenance dredging. In corporation Into aquatic and terrestrial ecosystems, and other loss mechanisms. Comment: The potential environmental Impacts of a series of hot-spot dredging and disposals over many years, as would occur If New York DOT had to deal with each spot as It should. Is never addressed. (Cohn, Chief, Planning Division, North Atlantic Division, COE, New York, New York). Response: The potential problems associated with the series of hot spot dredgings and disposals that would occur under the no-action alternative from routine maintenance dredging were recognized In the DEIS as an added justification for the dredging project. The DEIS (page 5-9 of the Executive Sunnary) states that rmnoval of PCBs from the upper Hudson River would reduce the risk of conducting environmentally unsound maintenance dredging and upland disposal of PCB-contaminated sediment. On page 4-8, the possibility of having multiple upland disposal sites of PCB-contaninated sediments derived from maintenance dredging was referred to as a significant, long-term, adverse Impact of the no-action alternative. Although disposal of PC8 contaminated sediments with con centrations of 50 ug/g (ppm) or greater would be regulated under TSCA, many disposal operations of spoils with lower PCS concentrations would not. In such cases, disposal and monitoring requirements dictated by the State are less stringent than those required under TSCA. The dredge spoil sites would not be as carefully designed, constructed and monitored, and could create greater risks to public health, compared to the proposed containment facility. In addition, numerous such sites would be required to accom modate spoils from maintenance dredging as shoaling occurred. Comment: The primary current environmental threat, as found by the Environmental Impact Statement, Is that of PCB hot spots being washed downstream during flooding. Inadequate dis cussion has been held as to the control of waterflow In the Hudson River; (Congressman, United States House of Represen tatives, Washington, O.C.). 3-30 HONS 009349 Response: A discussion of the flood control alternative Is contained In the OEIS (Chapter 2, Section 2). The alternative Mould Involve controlling flows from Great Sacandaga Lake at the Conkllngvllle Dm* to avert high flow periods In the Hudson River that would resuspend PC8-1aden sediments. Based on a review of the present system of flow controls In the Hudson River, control of major floods over the long term was found not to be a feasible method of controlling re suspension of PCBs. Controlling river flow would conflict with hydroelectric power generation and navigational use of the river. Water levels In 6reat Sacandaga Lake cannot be permitted to fluctuate too widely because of existing shoreline development and recreational use of the lake. Flow control systaas In the upper Hudson may be useful for short-term mitigation of flows, and they will be utilized as much as possible during the dredging operations, as discussed In Appendix A. Comment: There are some alternatives, however, that we feel could have received more extensive discussion, __Activated Carbon Ad sorption (p. 2-12) Is described as 'very reasonable* when compared to the cost of other alternatives, but Is dropped from further consideration because It has never been tested In-river, and because not much Is known of Its effectiveness or technical feasibility. Perhaps one or more of the 'hot spots* could be removed using this technique to determine If It could reduce the two (2) percent loss to the water column expected with the use of hydraulic dredging (pp. 4-42, 4-43). (Fear, Captain, U.S. Coast Guard Chief of Staff, Third Coast Guard District, Governors Island, New York). Response: Activated carbon removal of PCBs from the Hudson River sediments would Involve applying activated carbon to the river bed, allowing It to absorb PCBs, and then recovering the PCB-laden carbon from the river. NYSDEC and the PCB Settlement Advisory Committee considered this alternative and decided that It was presently technologically and econo mically Infeasible. The process is only In very preliminary stages of development, and at least several years of research would be required to develop a method. In addition to the costs of purchasing, applying to the river bed, and recover ing the activated carbon, costs would be Incurred In the treatment or controlled disposal of the PCB-laden carbon. Activated carbon removal was studied as a possible method of removing kepone from sediments in the Janies River, Virginia, but was found to be uneconomical (Tofflemire, NYSDEC, July 30, 1981). 3-31 HONS 009350 V-5. V-6. Count; The cost estlute should accurately reflect the double costs of both dredging the PCS material and encapsulating It In a landfill, and the cost to remove and destroy the sludge material once a safe method of destroying the PCS sludge Is developed. The disposal site Is designed for permanent disposal rather than temporary storage and this appears to be In violation of the EPA regulations which require that PCBs be destroyed by Incineration or the new PCBX process. The Solomon Amendment which passed the 96th Congress and was signed Into law by the President, states *no pollutant removed pursuant to the dredging shall be placed In any landfill unless the Admini strator first determines that the disposal of the pollutants In such- landfill would provide a higher standard of pro-.- tectlon of the public health, safety, and welfare than disposal of such pollutants by any other method including, but not limited to. Incineration or a chemical destruction process.' Also, much of the scientific comawnlty Is In agreement that the Northeastern United States Is tnvlorn- mental ly unsuitable for a secure landfill. The EPA no longer Issues permits for such landfills. These enviornmental questions should be answered before any further steps to dredge and dump are taken. (Solomon, Congressman, United States House of Representatives, Washington, O.C.) Response: At the present time, there Is no proven cost-effective method of destroying PCB-contamlnated sediments. All known des truction processes are either technologically or economically unfeasible because of the large amount of dredge spoils that would be Involved with both the full-and revised-scale projects (Chapter 2, Section 4A of the DEIS). The PCBX process developed by Sun Ohio Is only suitable for detoxify ing PCB-cqntamlnated oils. Comment: EPA Is aware of a soils detoxification process proposed by the Franklin Research Institute, Philadelphia, Pennsylvania. In order for this process to be effectlvje, however, the dredge spoils must be dewatered, as will be done In the proposed containment site. If the Franklin process proves effective and Is not excesslbly costly, the process will be used to detoxify the contaminated dredge spoils prior to final closure of the facility. To put Into perspective, how much PCB-contamlnated sediments could Wright Malta Corp. handle with their Incineration process? Hhat does the Wright Malta Corp. have to say in 1981? (Shapot, CAC. Cold Spring, New York). Response: The Wrlght-Malta process for detoxifying PCB-contaelnated dredge spoils Is a steam gasification process. The spoils are heated in the presence of water, and the coadnistlble gases that are formed are extracted and piped to a second stage combustion chamber of a gas turbine. Theoretically, 3-32 MOMS 009351 the turbine can be used to generate electricity. Wrlght- Malta says that a research program should be funded to develop the process. (Coffman. Wrignt-Malta Corporation. March 13. 1981). The process, however. Is only In a very preliminary stage of development, and its technological and economic feasibility are totally unproven. For this reason, NYSOEC and the PC8 Settlement Advisory Committee decided not to provide full funding to the project. If the process is developed, contaminated sediments would have to be dredged from the Hudson River, adequately de watered, and stored until they can be treated. If the process does become feasible in the future, these initial steps will have already been completed by the presently proposed dredging and containment project. V-7. Comment: Spoil disposal techniques such as the Bench-Scale Steam Gasification Dredge Spoil process, Goodyear's Chemical Degradation process and General Electric's Biological Degra dation process are also described as effective in the labo ratory but not yet feasible for Hudson River sediments on a large scale (pp. 2-39, 2-40). It should be stated how far away these systems are from practical use and how they are likely to compare with the proposed disposal process in terms of operational effectiveness and environmental impacts. (Fear, Captain, U.S. Coast Guard Chief of Staff, Third Coast Guard District, Governors Island, New York). Response: The Uright-Malta steam gasification process and other detoxi fication processes for PCB-contaminated sediments are still In preliminary stages of planning and development. How long it will be before these processes become available for practical use is difficult to determine because their deve lopment is highly dependent on available funding for re search, projects need for the processes, and other economic incentives, as well as technological developments (see comments Y-5 and Y-6). Almost all potentially feasible PCB-detoxIfication procedures require that the containment be removed from the river, adequately dewatered, and tem porarily stored until treatment. Therefore, the present plan for dredging and storage of contaminated sediments is con sistent with any PCB-detoxification processes that are developed in the future. VI. OTHER COMMENTS A variety of the comments received on the OEIS do not fall into any of the previously discussed categories. These comments generally were concerned with the following subjects: __ Remnant deposit alternatltves; e Unknown source of PCBs in the upper Hudson River- 3-33 hong 009352  Future development of hydroelectric power; e Coordination of the dredging project with NYSDOT maintenance dredg ing; e Natural decay of PCB aroclors; and a Other public health concerns. VI-X. Comment: ' Approximately 7200 lbs per year of PCBs pass over the Troy Dam (DEIS 1981), and 7300 lbs/year volatilize into the atmosphere (MPI 1980). About half of the volatilized PCBs may come from contaminated dumps and spoil sites (MPI 1980). Provisions for these sites have been eliminated In the rescoped project. The effect of this elimination has not been spelled out clearly in the DEIS, and should be more fully explained in the FEIS. The DEIS also states that an unknown source of PCBs may be contributing to the PCB load In the river. No estimate Is given about the amount It sy be contributing. Ue believe that a study should be made to locate such a source, should It exist, so that Its mitigation may be Integrated Into the dredging as a whole (Natural Resources Oefense Council, Inc. New York, New York). Response: The EPA recommended project, both full- and reduced-scale. Includes provision at the containment site for PC8-contartnated materials from other spoil sites which may be found to be releasing significant amounts of PCBs to the air or groundwater. Under recent settlement between NYSOEC and General Electric, the contaminated dumps are being studied and remedial actions are being taken to prevent these sites from contaminating air or groundwater. As part of the pre-dredging baseline monitoring program designed by NYSOEC for the dredging project (described In Appendix A), the presently unknown source of PCBs In the upper Hudson River will be Identified, and remedial action, such as removal will be undertaken. If a significant action Is required within the scope of this project, a separate environmental assessment for this project modification will be Issued before dredging Is undertaken (see comment VI-2). VI-2. Comment: I am concerned that if the EIS Is published with Table S-l as currently drafted, DEC will not have the needed flexibility to rescope the project, should rescoping be required once the `mystery source* is Identified. For example. If the source turns out to be the remnant deposits, several of these deposits may need to be removed. If the source turns out to be discarded barrels or dump leachate, clean-up of those problems may become a priority. I fear that the current EIS could lock DEC into pursuing the reduced scale as outlined on Table S-l, even though a some what different project may be more effective. To address the 3-34 HONS 009353 VI-3. "mystery source*, in such a case. Mould require the depart ment to seek additional funding, with all the delays that Mould entail, even if the source Mere discovered to be a major contributor of PC8s floning over the Troy Oam. I recommend that the EIS should be altered to clarify the possibility of rescoping to address removal or mitigation of the `mystery source*, and that a process should be provided to facilitate any supplemental assessments such a rescoping may require. (Hhyatt, Scenic Hudson, Inc., and the Hudson River Fishermen's Association). Response: As part of the pre-dredging monitoring program, NYSOEC Mill conduct a survey to identify the unknoen source of PCBs in the upper Hudson River. If the source is determined to be the remnant deposits, the project has the flexibility of being rescoped to remove or mitigate PC8 losses from the remnant deposits. Any project modification, however. Mould need to: pertain to removal of contaminated material from the river; undergo an environmental assessment; and be approved by EPA. Limited studies already completed by NYSDEC have not Indi cated that the remnant deposits are a lively source for the unaccountable floe of PCBs in the upper Hudson River. Comment: I understand that the proposed program does not Intend to remove PCB Materials from above the old dam. In fact, it Is understood that remnant deposits designated as No. 4 and 4a are intended to be left in their present condition. Remnant deposits 4 and 4a are of vital concern to this Corporation since this is the location of the recreation site noted above. (Harold E. Rist, Hudson Heights of Moreau, Inc., Glens Falls, New York). Response: Remnant deposits 4 and 4a contain lower concentrations of PCBs compared to deposits 3 and S, based on NYSOEC research (Chapter 2, Section 2 of the DEIS). Remnant deposits 3 and 5 would be capped and further stabilized under the full- and reduced-scale projects. Based on data from other sites correlating volatilization rates and concentrations of PCBs In sediment and soils, NYSOEC has estimated that PCB levels in the air above remnant deposit 4 and 4a do not exceed the NYS00H guideline of 1 ug/cu m. As part of the background monitoring program designed by NYSDEC (appendix A), air levels of PCBs at the remnant deposits will be measured to confirm previous esti mates. If the PCB levels are found to be excessive, remedial actions will be recommended. 3-35 HONS 009354 VI-4. VI-5. VI-6. Coonent: Although Niagara Mohawk's plans for rebuilding the Fort Edward Daw appear to have been dropped for the tine being. I think the EIS should Include a recommendation that the remant deposits should be removed or further stabilized (to prevent PC8 leaching due to a fluctuating water level) if the dan Is ever reconstructed. (Whyatt, Scenic Hudson, Inc., and the Hudson River Flsheman's Association). Response: The Inpact of the proposed project on development of hydro electric power at Fort Edward has been addressed on page 4-34 of the DEIS. Because of public health and environmental considerations. In-place stabilization of remnant deposits was the alternative recommended in the DEIS. If the remnant deposits are discovered to be a significant source of PCBs to the river, however, additional mltigatlve measures will be taken. It Is not within the scope of this OCIS to address future development of hydroelectric power on the Hudson River. Any future action utilizing the Hudson River which may have an Inpact on the remnant deposits would have to be evaluated at that thee. If such an action would cause a disturbance of the remnant deposits, mitigation measures, such as further stabilization or removal, would have to be considered. Comment: We believe that the DEIS does not give consideration to the Impact of the proposed reclamation project upon energy development, particularly under the reduced-xale project. We recommend, therefore, that the Environmental Protection Agency amend the DEIS to consider hydroelectric development In formulating the overall project and In setting priorities for the removal of PC8s from the river. (Vessels, Director, Office of Envlroneental Planning, State of New York Depart ment of Public Service, Albany, New York). Response: The Congressional authorization under which the dredging project was initiated authorized EPA to undertake a demonstratlon/reclamation project for removing and disposing of PCB-contamlnated sediments from the Hudson River. Possible electric power generation at Fort Edward was considered In assessing Impacts In the DEIS. Future hydroelectric develop ment was not a priority In formulating the overall project design, however, because It was outside the xope of the legislative authorization. Comment: A major shortcoming of this project has been Its failure to consider current private and state dredging operations. Procedures should be developed and sufficient capacity retained in the disposal site to at least accommodate those operations to be undertaken concurrently with this project. Added costs could be assessed to the state DOT and private 3-36 HONS 009355 VI-7. applicants. Mho Mould benefit from not having to design Md build their own sites. The environmental Impacts Mould be lessened In having only one heavily monitored and controlled site built to tight specifications. And an attempt at managing upriver activities Mould have begun. It may not be possible to coordinate all activities, but no attempts have been made, despite numerous comments from this district. Once the Site Mas closed, upon project's completion, no additional material Mould be placed Mlthin. (Cohn, Chief, Planning Division North Atlantic Division, COE, NeM York, Ncm York). Response: Under legislation recently passed by the NeM York State Assembly and Senate (yet to be signed Into 1*m by the gover nor), the proposed containment site Mould be authorized to accept only those PCB-contamlnated sediments from the Hudson River between Lock 2 and the village of Fort Edward. The site could not be used for the disposal of any other hazar dous wastes. Any dredging and disposal operations undertaken by NYSOOT or private applicants Mould have to be done concurrently with the proposed dredging project, with authorization by NYSOEC, and also meet the legislative criteria described above. A recommendation of the CAC Incorporated into the Executive Summary of this Supplemental DEIS was that NYSOOT develop a comprehensive dredge spoil disposal plan for the upper Hudson River. Such a plan Mould help to ensure coordination of NYSOOT dredging activities with the proposed project. Comment: New York State's tentative finding that the heavier PC8 fractions are not degrading as rapidly as the lighter ones... appears to have ramifications for both fisheries and water supply. These complications should be included in the assessment of Impacts. (Rehfus, Services Division, Habitat Protection Branch, National Narine Fisheries Service, Gloucester, Massachusetts). Response: PCS aroclors discharged Into the Hudson River varied in the weights of chlorine contained In the mixtures (pages 1 and 2 of DEIS). The principal forms of PCS discharged were aro clors 1242 and 1016, which are low chlorinated aroclors. Lesser amounts of aroclor 1254, a higher chlorinated aroclor, were also discharged. There is evidence that the low chlori nated aroclors are less stable and subject to slightly greater degradation In the environment than the highly chlorinated aroclors, such as 1254. A decline in PCB levels 3-37 HONS 009356 VI-8^ VI-9. VI-10. In Hudson Rlvor fish observed by NYSOEC ms probably pertly caused by declines In the Ion chlorinated aroclors. Analysis of fish by NYSOEC in 1980 indicates that levels of 1254 are declining very slowly If at all. The significance of this Is that PCBs may exhibit long-term persistence In the water, sediments, and biota, even though Initial declines of less stable aroclors may have occurred after PCB discharges by General Electric were halted. Conment: If the DEC and EPA are as concerned- about public health safety as they say, irfiy Is GE allowed to have an uncovered chemical pool In a neighborhood? (Brown, Fort Edward, New York). Response: Remedial action for the General Electric dump sites Is presently underway under NYSOEC regulatory action. The above comment may refer to a storm water retention pond on General Electric's property. Comment: [Occupants of] ten out of fourteen houses In our neighborhood have either: blood diseases, cancer, respiratory problems, female disorders or miscarriages. Does this ratio merit further research as to the health hazards Imposed by PC8s and other chemicals before dredging? (Brown, Fort Edward, New York). Response: One of the goals of the PCB dredging project Is to reduce the aaount of unconfined, PC8-contam1nated sediments and dredge spoils In the upper Hudson River region. PCB contamination has adverse Impacts on the environment and poses a risk to public health and welfare In the region. The analysis presented In the DEIS Indicates that the actual dredging operation will have only local, short-term Impacts on biota and water quality. There will not be significant long-term adverse Impacts on public health from the dredging project, and. In the long term, the project will reduce the amount of PCB contamination in the region. Any unusually high incidence of diseases In localized areas, especially areas exposed to potentially harmful contaminants, warrants further investigation. Such Investigations are the responsibility of the NYSDOH. Comment: - The attached document is In response to your 4 Nay 1981 announcement regarding the DEIS for the Hudson River PCB Reclamation Demonstration Project. It summarizes our com ments on Appendix C concerning the review of our PCB modeling work. In general, we find the review to be both inaccurate and misleading. Based on the Information presented In the 3-38 HONS 009357 attached document. we request that this review (Appendix C of the DEIS) either be removed from the final EIS or revised to reflect our attached comments, but certainly not left as is. (Abood, Partner, Lawler, Matusky and Skelly Engineers, Pearl River, New York). Response: The sediment and PCB transport model prepared by Lawler, Matusky and Skelly Engineers (LMS) and reviewed In Appendix C of the OEIS provides estimates of PCB loadings from the upper Hudson River to the estuary. The model provided an adequate assessment of PCB transport conaensuate with the data, time and budget available. Explanation of the model selection procedure and application is available in a variety of interim reports, memos, and other supporting documents available from LMS. The model was chosen to fit research objectives as well as available data. Although the review of the model presented in the DEIS points out certain weak aspects of the analysis, the model did provide the best available estimates of PCB loadings In the Hudson River. 3-3s HONS 009358 Federal, State, Local, and Other Sources from Which Comments Have Been Received Abbreviations Used Corresponding Metric and English Units References List of Preparers HONS 009359 FEDERAL, STATE, LOCAL AND OTHER SOURCES FROM WHICH COMMENTS HAVE BEEN RECEIVED Federal Agencies: Army Corps of Engineers Department of Agriculture, Soil Conservation Service Department of Health and Human Services Environmental Protection Agency Fish and Wildlife Service National Marine Fisheries Service United States Coast 6uard United States House of Representatives: Honorable Gerald Solomon New York State Assembly: Honorable Joseph Ferris Honorable Joan Hague State and Local Agencies: City of Albany City of Poughkeepsie New York City Department of Ports and Terminals New York Farm Bureau New York State Department of Environmental Conservation New York State Department of Health New York State Department of Public Service Port Authority of New York and New Jersey State of New York Department of Agriculture and Markets Warren-Washington County Farm Bureau - Citizens Group: Citizens Advisory Committee to the Dutches County Legislature Citizen-Environmentalists Against Sludge Encapsulation Hudson River Clearwater Sloop, Inc. Hudson River Fishermen's Association International Union of Operating Engineers Local 251 National Audubon Society New York Towboat and Harbor Carrier's Association PCB Citizens Advisory Committee PCS Settlement Advisory Committee Save Our Port Seafarer's International Union . Sierra Club United New York and New Jersey Sandy Hook Pilots Association 4-1 MOMS 009360 ASEMCIES (continued) Others: Steven Allen Oebbie Broun Cherlotte Burkhardt Edward Coffin Berry Cutle Henry De Groot Robert Eddy Leroy Fein Hudson Heights of Moreau, Inc. Irene Kleiaentowlcz Lawler, Matusky and Shelly Engineers Buy Matthews Jeannlne Matthews Ellen Mulvaney George Mulvaney Karen Seelzl Ralph Shapot MOWS 009361 4-2 00936j CAC cl as COE cu ft cu m cu yd DEIS EIS EPA FOA ft 9 hr In kS In 1 LMS 1b m nev mg ml mm HP I mrcni ng NEPA NIOSH NYSOEC NYSOOH NYSOOT ABBREVIATIONS USED Citizens Advisory Committee curie centimeter United States Army Corps of Engineers cubic foot cubic meter cubic yard Oraft Environmental Impact Statement Environmental Impact Statement United States Environmental Protect!* United States Food and Orug Adeintst foot gram hour thehe kilogram kilometer liter Lawler, Matusky and Skelly Engl* pound meter million electron volts milligram mile ml 11imeter Malcolm Pirnie, Inc. millirem nannogram National Environmental Pol National Institute for to New York State Department New York State Departmen New York State Departmar Occupational Safety and) ' '"htorinated hyphen; ABBREVIATION USED (contlneud) PCOf pci ppb PPt SAC sec sq ca sq m TSCA USOA USFWS 9 r polychlorinated dibenzofuran plcocurle parts per million part per trillion PCB Settlement Advisory Committee second square centimeter square meter Toxic Substances Control Act United States Department of Agriculture United States Fish and Wildlife Service microgram year HONS 009363 5-2 .CORRESPONDING METRIC ANDJNGLISH EQUIVALENTS Celsius (*C) centimeter (cm) cubic meter (cu m) gram (g) hectare (ha) kilogram (km) kilometer (km) liter (1) meter (m) metric ton (t) microgran per gram (ug/g) microgram per liter (ug/1) milligram per liter (mg/1) millimeter (mm) nannogram per liter (ng/1) NOTE: 1. an approximate equivalent Farenheit(*F) inch (in) cubic yard (cu yd) cubic foot (cu ft) gallon (gal) pound (lb) acre (a) pound (1b) mile (mi) gallon (gal) yard (yd) foot (ft) ton (tn) part per million (ppm) part per billion (ppb)1 part per million (ppm)1 inch (in) part per trillion (ppt) 6-1 HONS 009364 REFERENCES Bopp, Richard F. 1979. Tha geochemistry of polychlorinated biphenyls in the Hudson River. Ph.O. Dlsertatlon, Coluabla University. New York, New York. Bopp, Richard F., H. James Simpson, Curtis R. Olsen and Nadia Kostyk. 1981. Polychlorinated biphenyls In sediments of the tidal Hudson River, New York. Environmental Science and Technology. 15(2): 210-215. Coffman, J.A. (written communication). March 13, 1981. Letter from J.A. Coffman, Chemist, Wrlght-Malta Corporation, Ballston Spa, New York, and J.E. Sanders, Chairman, Hudson River PCB Settlement Advisory Committee Barnard College, Columbia University, New York, New York. I Dewiest, R., 1965. Geohydrology, Wiley, New York, New York. Malcolm Plrnle, Inc. 1980a. PCB hot spot dredging program, upper Hudson River, containment site Investigations. Prepared for New York State Department of Environmental Conservation, Albany, New York. Malcolm Plrnle, Inc. 1980b. PC8 hot spot dredging program containment site, design report. Prepared for New York State Department of Environmental Conservation, Albany, New York. Malcolm Plrnle, Inc. 1980c. PCB hot spot dredging program, upper Hudson River, New York. Draft Environmental Impact Statonent. Prepared for New York State Department of Environmental Conservation, Albany, New York. Malcolm Plrnle, Inc. 1981. Draft PCB hot spot dredging program, upper Hudson River, New York, rescoping report. Prepared for the New York State Depart ment of Environmental Conservation, Albany, New York. Plrone, Dominick J., PCB Settlement Advisory Committee, June 24, 1981. Statement given by Dominick J. Plrone, Member, Hudson River PCB Settlement Advisory Committee, at the Public Hearing for the Environmental Impact Statement on the Hudson River PCB Reclamation Demonstration Project, held on June 24, 1981, at Poughkeepsie, New York. Rappe, Chrlstoffer. 1979. Dioxins, dlbenzofurans and other polyhalogenated aromatics: production, use, formation and destruction. Annals New York Academy of Sciences: 1-19. Sanders, John E. (written communication) June 26, 1981. Letter from John E. Sanders, Chairman, PCB Settlement Advisory Committee, Barnard College, Columbia University, New York, New York, to Edward W. Coffin, Poughkeepsie, New York. Thomas, Richard F. (written CoaMunlcatlon). No date. Response to Nr. Scelzl's letter of February 9, 1981. Letter from Richard F. Thomas, Project Manager, Malcolm Plrnle, Inc., Consulting Engineers, White Plains, New York, and James 6. DeZolt, Project Manager, New York State Department of Environmental Conservation, Albany, New York. 7-1 HONS 009365 Tofflemire, T.J. (oral communication). July 30, 1981. Conversation between T.J. Tofflemire, Senior Scientist, New York State Department of Environmental Conservation, Albany, New York, and Gregory T. Greene, Biologist, MAPORA, Inc., New York, New York. HONS 009366 7-2 LIST OF PREPARERS This Supplemental DEIS was prepared by HAPORA, Inc. under the technical direction of the following EPA Region II Environmental Impact Branch personnel: Robin Rohn Project Offlcer/Envlronmental Scientist Thomas Maher Project Offlcer/Environeental Engineer Richard Walka Chief, New York/Virgin Island Section The HAPORA staff members trto prepared this document and their areas of responsi bility are: Principal Author Gregory T. Greene Project Manager/Biologist Contributing Authors Alfred Anglola Kathleen Murray Chris Salmi Project Management/Air Quality Water Resources Air Quality/Pub 11c Health 8-1 HONS 009367 Appendices HQHS 009366 APPENDIX A Response to Executive Summary of Draft Environmental Impact Statement, Hudson River PCB Reclamation Project New York Department of Environmental Conservation, 1981. Response to Executive Summary of Draft Environmental Impact Statement, Hudson River PCB Reclamation Project, Albany, New York. HONS 009369 HUDSON RIVER PCB RECLAMATION PROJECT RESPONSE to EXECUTIVE SUIWRY OF DRAFT ENVIRONMENTAL IMPACT STATEMENT New York State Department of Environmental Conservation June, 1981 A-1 HONS 009370 Introduction Tbio report boo boon prepared bp tho bow York State Department ot Environmental. Conservation <DIC) in response to tho Executive Suaaurp of tbo Draft Environnental Impact Statement prepared bp the United States Environment tel Protection Agencp for tha Hudson Kiver PCS laclamation Project. Tho monitorin( and contingencp plans outlined in this response report era considered bp DEC to be a vital and integral portion of this project. In the event that contingencp plana are required to be implemented, thaae measures will bo authorized bp the DEC Project Director. The laboratorp data to bo utiliaed in faapact aaeasement will bo provided bp the DEC project laboratorp to tbo Environmental Monitoring Manager of DEC who will advise and nabs recommendations on a dailp baaia to the DEC Project Director of the statua of salient environmental parameters. Tha EPA and New York State Department of Health will bo provided with copiaa of all data collected' aa part of tha environmental nonitoring program. Prior to tho dredging, a comprehensive baseline environmental monitoring program will be instituted. This baseline program is outlined in Appendix A ot this response report. Sampling procedure, location maps and a detailed description of tha Environmental Monitoring Program are contained in Appendix a of the Qualitp Assurance/Qua1iep Control being developed bp DEC as part of this project. A-2 HONS 009371 Throughout thi* dociaant, tha tarn haavy natal* or natal* haa baan otilixad. Thaaa tarn* ara. In all eaaa*i ara to includa tha following alananta: 1. Araanie 2. Cadniun 3. Chromium 4. Copper 3. Laad A. Mercury 7. nickel . 8. Zinc A- 3 MONS 0093 72 Project "Modifications" tocomawndod by the MEPA-DEIS Report Section ' Dredging, In-River Containment, and Stabilisation 1. Study and aaka recoenandationa to determine it aaiiaiu in-river contaimnant of hot spots vara foaaiblo and coat offoctivo. (This-will bo atudioa In detail during tho 43-day draft NRPA SIS review poriod.) I 2. Cap/in-placa atabilixatLon and danial of accaaa of raanant dapoaita II 3 and ] aa an i^aadiata naaaura. 3. Maximise uprivor flow rogulation at Saganadaga Dan aa a flood control noaouro during tho dredging operation. III 4. Develop operational atandarda and proceduroa, mitigating naaauraa nonitoring programs, and contingency plana to olinitiate eaceaeivw volatiliaation and roauapanaion of PCI-contaninatod aodinonto to protect workers, residence, agricultural roaourcea, and water auppliea. IT Diapoaal 5. Modify diapoaal operationa at the containment aita, including tha IT proviaion for aawller containment cella, addition of PCS adaorbonta and poeeible cell cover during loading operationa to niniaiaa volatilisation. 6. Develop operational atandarda and proceduroa, contingency plana, IT and nonitoring program surrounding the proposed eontainawnt aita for the duration of the diapoaal operations to assure the MTSDOH 1 ug/eu n ambient air guideline is met, aa well aa the 0.2 ug/g (ppm) standard for eropo sac by tho U.S. Pood and Drug Administration. 7. Develop specific contingency plana for additional treatment of the supernatant fron dswatering prior to discharge if permit limits (to be established) are exceeded. T Long-Term Storaga I. Development of long-tom maintsnanco and monitoring programs for a IT minianaa of 30 yoars with periodic program review by EPA and ITSDOR. P. Contingency plans for (a) long-term laachata collection and IT treatment, (b) landfill cap maintenance, (c) excessive PCI volatil isation or mothane generation, and (d) alternate water supply should nonitoring indicats failure of eontainawnt site. MOMS 009373 A-4 Froiact "Modificationa" tacomnandad by tha HEFA - DEIS Report Saction 10. Tin development of grievance and arbitration procaduraa and Cha lnvaatigation of cha faaaibilicy of liability inauranca for any claina ariaing in eonnaetion with tha public haalth aapacta of tha projact. VI 11. Froviaion for apacifie funding nachaniana by MYSDEC to aaaura t-Fl anantat ion of long-tara cont infancy plana, oparation, aaur tananca, and monitoring. VI 12. ladaaign of tha containnant aita laachata collaction and atoraga ayatan to inprova oparationa and to avoid clogging and buildup of laachata within tha aita. VII 13. Froviaion for atoraga of UTSDOT naintananca dradging natariala fron altaa 212, tl, 204 Annan from Vaahington County only (if rnaeval ia daanad nacaaaary), undar tha condition that tha atata baar tha incraaantal coata aaaociatad with diapoaal and long-tara atoraga. IV Watar Quality Monitoring 14. Dovalop a long-tarn aonitoring prograa to avaluata tha inprovanant IV of tha racovary rata of tha rivar and fiabariaa. 13. Dovalop a long-tarn monitoring and naintananca prograa if in-rivor containnant ia implaaantod to datarnina loaching of FCBa bach into tha rivar. -- ____ , I 14. Davolop a downatraaa public watar aupply monitoring program for PCSa and haavy natala to bu implanantad bafora, during, and aftar dradging oparationa, aapociatly during and ahortly aftar high flowa. Continfancy plana to provida additional watar traatannt or altarnata watar auppliaa alao ahould ba davalopad. IV 17. Davolop a abort-tarn monitoring prograa for air quality, watar quality, and biota during dradging and diapoaal oparationa. IV Citiaana' Adviaory Commit tea Sacoaamndation IB. MTSDEC ahould conaidar providing aaaurancaa Chat naithar tha pro- VIII poaad containnant aita nor tha aurrounding land acquirad by Maw York Stata will ba uaad for tha futura diapoaal of any haxardoua waata ganaratad fron aithar within or outaida Haahington County. A- 5 HONS 009374 I. Ill rim COWTAIHUHT OF HOT SPOTS 1. General 1h DEIS recommended niaiuCiaa of tn-river containment of hoc apota whara faaaibla. NYSDBC etudiea ahow thia aa a poaaiblo alcarnaclvc Co dredging hoc spec* S and 33. Thla would ba accoupliahed by Cha conacrucciou of a patCial porSaMCtr rock dike ac aach hoc apoC. Tho purpoaa of cho diking ia Co preface cho hoc apoC froa acour during low flood flowa. Thia alternative haa boon evaluated on cha baaia of tea coaC and affaccivanaaa in inhibieing eba Cranapore of PCBa both co cha waear column and Co Cha biota. The allgnaant and a typical auction of cha partial perimeter diking ayetam ia praaantad on Platea 1 and 2. 2. Hock Diking The dike icaalf would conaiat of a ccneral corn of cruahad atone aand or othar appropriate notarial covered by a one-foot layer of intermediate aiaed atone and topped with two feet of riprap. The dikea will have a Cop width of Can feet and aide alopea of 2.3 horizontal on one vertical. The height of the rock dike will ba approximately three feet above Che normal pool elevation conaiatene with elevaciona of two to five year flood occurrencea. The dike will extend three feet into Che river bed. Bed aediaanca removed for dike conatruccion would be dredged and traneported to Cha containment aite. The diking muat hava a rugged atructure to withatand flood flowa, ice and wave weak from canal eraffic. There dikea would require continuing, long-tern maintenance in order to retain atructural integrity. 3. Hot Spot 6 Hot Spot 8 haa the largeat volume of the 20 hoe apota in the Thompaon Ialand pool. It haa a dredge reooval volume of 162,300 cu. yda. containing an eatiaatad 18,000 pounda of FCB. M0NS 009375 A-6 Two tltarnaciva dika Khaaaa are presented for hot spot g. A1 ternative A coneilt* of a eontinuoue 3,500 ft. long dika bordering 45 percent of this hot spot. Alternative B consist* of throe sull dikes with a combined length of approximately 330 ft. connecting the island at the north end of the hot spot. Thgis islsnd/dika system border* 20 percent of hot spot B. The altsrnacivs diking systems are shown on Flat* 1. Under Alternative A the dike would have an average height of 3.5 feet above the bed. Estimates for alternative A were mad* using the sections done as part of tho Hudson liver `i Survey, 1976-1977, by Hormandeau Associates,. Inc. Under Alternative A, the dike sections would have an average height of 5.5 feet above the bed. Alternative B estimaes were based upon field Information gathered by Dr. James 1 offlemire of the NTSDEC. Hot Spot 8 would be dredged under the rescoped reclamation project. Under Alternative A the cost of the diking would be approximately 81,025 per linear- foot for a total cost of 33,252,000. The cost to dredge, and transport the entire hot spot has been estimated previously to be 31,947,000 (1981 dollars). This inlcudes treatment of the dredge slurry water before discharge to the Hudson River. Under Alternative 2, the.cost of diking would *>* approximately 3590 per linear foot for a total coat of 3195,000. This does not Includa the cost for protection at the dike-island interface. The cost to dredge, transport and treat the remainder of the hot spot would be approximately 31,100,000 (1981 dollars) for a total cost of approximately 4',300,000 for the entire hot spot. A summary of costs is presented in Table 1. 4. Hot Spot 35 Hot Spot 35 has a dredge removal volume of 27,250 cu yds containing an estimated 2,100 pounds of PCB. HOMS 009376 A-7 Th dike evaluated (Plate 2) would ba 300 feat long and bocdar 33 pareant of thia hot apot. Tha dika would have an average height of aix faat above tha bad. Thaaa estiaates wara aada uaing a aingla aaetion dona in thia araa aa part of tha Hudson giver Survey 1976-1977, by Noraandeau Aaaoeiataa, Ine. and information gatharad through fiald investigations by Dr. Jamaa Tofflamlra of tha HYSDgC. Dr. Tofflamira'a invaatigationa indicata that rivar. dapthar of tan faat will ba aneountarad if tha dika ia extended arthar than 300 faat. Tha coat of diking would ba approxiaataly $770 par linaar foot for a total coat of $230,000. Tha coat to dradga, transport and traat tha dradga slurry for tha antira hot apot has baah astiaatad praviously to ranga batwaan $339,000 and $360,000 (1991 dollars). Hot gpot 33 has baan idantifiad aa containing a significant watland undar tha raaeopad proajet and was tharafora givan a low priority for raaoval. 3. Pravioua In--Xivar Containaant Bvaluationa ' Pravious avaluationa hava baan dona on two additional typaa of in-rivar hot spot containaant. Shaatpiling has baan avaluatad aa an altarnativa to rock diking and placcaant of a rock blankat ovar contaminated araaa haa also baan conaidarad. Tha coats for single sheet piling wara found to ba eoaparabla to tha eoat of rock diking. Tha faaaibility of this opcioa would require further study. Tha coat of placing a rock blankat ovar a contaainatad araa was astiaatad at $160,000 par acra, or ovar $20 aillion for tha Thoapaon Island hot spots. 6. Coat Summary A cost atsuaary for both diking and dredging Hot Spots 9 and 33 is praaantad in the following table. HONS 009377 A - .8 TAILS t cost swoubtO) Dika - Langth - Haight (avaraga) - laaa Width (typical) - Voluaa (total) - Dika Construction Coat ' Hot Spot - tanoval .| - lanoval Votuna Bordarad bp Dika i - Avaraga PCD concantration (In-Situ) - Pounda of PCI (total) - Pounda of PCI lordarad by Dika - Coaiplcta lanoval-Dradging Coat Unit Coat Comparisons - Diking 8/lb PCI lordarad . i - Dradging Coat S/lb PCI Ranovad (1) All coats ara praaantad in 1911 dollars. Araa ____________________________ Hot Spot > Altarnativa A Altarnativa I Hot Spot IT 3, 170 ft. 9.3 ft. 58 ft. 53,600 cu yds 83,252,000 330 ft. 5.5 ft. 38 ft. 3,100 cu yds 8195,000 300 ft. 6.0 ft. 40.0 ft. 3,700 cu yds 8230,000 162,500 cu yds 71,000 cu yds 99 ug/g 18,800 lba 8,200 lbs SI,947,000 162,500 cu yds 37,000 cu yds 99 ug/g 18,800 lba 4,300 lba 81,947,000 27,230 cu yds 15,000 cu yds 105 ug/g 2,100 lbs 1,100 lba 8338,000-8560.000 S 390 8 45 8 205 S 105 8 105 8 160-8270 HONS 0 0 9 3 7 0 * 7. hill for Diking Hot gpt a and 38 The concept of diking Hot Spot* S and 33 i baaed upon aeveral aaauoptiona: * Conacrue Cion of tha dike will aignif icantly raduca Cha amount of PCS tranaporead from tha hot apot to tha watar column * Tha coat of conatrucitng tha dlka will ba laaa chan tha coat of dradging tha hoe apot ' Tha dika at Hot Spot 33 will aaintain tha integrity of the watlaad araa whila conatraining further Migration of PCBa Seduction of PCS Tranaoort - Although thaaa dikaa would reduce tha potential for acour during low flood parioda (2 to 5 year flood occurreacea ), they would do little to roduco acour during high flood perioda. Tha exiatenca of watlauda would tend to aupport tho argument that acour ia already uiniual in thaaa areaa under low flowo.. In addition, tha emitting highway embankment now protacta tho area that would bo bordered by tho propbaad dika. Coat - Under Alternative A, the coat to conatruct tha diking for hoc apot S ia coneiderably highar than tha dradging coat for thia area. Tha coat of the diking for hoe apot S nudor Altarnativo B ia half the coat of dradging par pound of PCS removed. Tho coat of conatructing Alternative B diking and dradging tho remainder of tha hot apot would bo one third laaa than dradging the entire hat apot. Ac hot apot 33, tha coat of diking falla within tha range of dradging coata. Low watar deptha would cauae aoue difficulty in accent for dradging reaultlng in an increaaa in tha average pool dredging coat over that given in Table 1. Wetland Integrity - The conatruatlon of a dika will reduce tha traaefer of water and aad inane through the wetland area thereby altering lea preaant equilibrium. HONS 009379 A - 10 8. Monitoring - The following additions would bo undo to tho projoat Mattering program if any of tho proposed diking Matures ara inplewantod. * Visual inapaetiona of the structural integrity of tho diking at regular intervals. ' * Monitoring of a sariat of cross aaccions across the affected hot spot areas to dateraina tho extent of scour and deposition after the placament of diking. * Monitoring of tha water coIum at tha intarfaca between tho affected area and tha Hudson tivar to dateraina tha rate of PCI exchange. . Summary It appears that some partial stabilisation Matures could be done la areas of shallow water depths for lass than the cost of dredging. Significant questions remain, however, concerning tha following itaM. * .The affactivanass of partial stabilisation with raspact to tha transfer of PCS to tho water coIum and aquatic biota during low flows. * Tha affactivanass of partial stabilisation with raspact to scour during floods in axeaes of tha 2 to 5 year flood levels. * Tha affects of containMnt dikes on peasant rivar conditions, a.g., stagnant watar, silting, affects on wetland charactaristica. * Interference with tha navigational channel - tha diking of hot spot S under Altarnatlvo A has tha special case of bordering on tha navigational channel in soma areas. ' Tha affects of tha dikes on local flood and bank stability conditions. A - 11 HONS 009380 HUDSON RIVER PCS RECLAMATION PROJECT RESPONSE TO CONCERNS RAISED IN NEPA-EIS JUNE 1981 Appendix -E.P. TOXICIT TESTS No additional E.P. toxicity teata wara run by Malcolm Pirnia on too Thompaon I*land Pool aamplaa labalad Cora No. 152 (hot apot IS) and Compoaita of Cora Nos. 15, 84ss and I35sa. Tha rasults of tha natala taata aro liatad on Attactaaanc A. Appandix - ELUTRIATE TESTS Tan alutriata Casts ara plannad Co davalop data to ganarata applieabla partition coafficianca for aamplaa under-various combinations of PCS concantratoio, grain sisa and volatile solids contant. The testing will consist of tha following stops: * Screening of rivtr bod smaplas in terms of grain aixa and volatile solids * PCS and metals analysis on tha river bad sediment * Elutriate Casts performed on Che tan salaetad samples * PCS and metals analysis on tha alucrisca Tha alutriata Casta will ba dona in accordance with Appandix A: Elutriate Tost Procedure in Ecological Evaluation of Proposed Discharge or Pill Material into Navigable Waters. Dredged Material Research Program, Miaeollaneowe paper D-76-17, May 1976, Final Report. The samples have been received by Malcolm Pirnia and the screening of samples has begun. Test results will be forthcoming. a - to HONS 009381 II. EEMHAHT DEPOSIT REMEDIAL ACTIOHE I. General The runt dtpoiiti are PCI-cmtiaiiMUd areas adjacent: co tha Hudson River upatreoi of the fonaar Fare Edward Dan. These areas ara Che resuins of 150 years of deposition behind the den, now exposed as dry land following dan renewal in 1973. Much of tha deposited notarial haa washed downstream; those areas which renain have been designated rennant deposits. Under the original HT3DEC proposal (full-scale project) rennant deposit areas 3 and 5 wars to be excavated and transported Co the upland containnene site. Due to funding linitations and after a priority raview of project components, renewal of these areas was elininated under the rescoped project. Top dressing and fencing of both areas was proposed in the RRFA-DEIS for two reasons: volatilisation of PCBs fron thaaa areas and the frequenting of thaaa areas by local residents for general recreation and dirt biking. Tha rennant deposit areas are the nose stable of Che PCB-contaninatcd naterials in the project area. Bank stabilisation conpleted in 1977 protects these deposits fron erosion for up to tha 100 year flood flow. Additionally, their resMta location and natural inaccessibility provide an effective barrier to human traffic. Air contamination from these areas is not significant as shown by intensive air nonitoring at various locations in Fort Edward and Hudson Falls and adjaceat to these areas. This monitoring indicates PCB in air levels of less than 0.1 ug/m3 from these areas and ocher sources. This falls far balow the 1.0 ag/m3 safety guidelines sec by HTSDOH for residential exposure. However, the following resiedial actions may be taken at remnant deposit areas 3 and 5 Co reduce FCB volatilisation and further limit and discourge public access: A - 13 HONS 009382 * An organic top dressing map bo placed at remnant dapoait araaa 3 and 5 to minimiaa PCS volatilisation. * Existing fencing mj bo repaired, replaced or extended at area 3 to limit public accaea. * Perimeter fencing nap bo inatalled at area 3 to limit public ---------- accaaa. * Warning eigna map bo posted at both area 3 and area 3. 2. Top Praising To reduce PCS volatilisation a minimum of 12 inchea of organic top dressing map be placed on both areas 3 and 3. Thia organic cover will reduce volatilisation in several waps: * lp providing a medium which, due to ite organic content, will crap pegs which are migrating upward * Bp providing a barrier between wind and the PCB-contaninated material. * Bp providing an added taper of insulation to reduce temperatures at the surface of ehe contaminated material. The placement of cover materials such as topsoil, paper mill sludges and manure have previouslp been effective in minimising PCS volatilisation at the Caputo disposal alts near South Ciena Falla. Three alternatives which would be effective for a long-term cover at the raseiant deposit areas ara: * A minimum of three inches of sawdust covered with a minimum of nine inches of fine grained, organic soil or a soil-manure mixture. * A 12-inch taper of a. fine grained soil-manure mixture. * A nine-inch leper of a sand and paper mill sludge mixture covered bp a minimum of six inches of Cop dressing. HONS 009383 A - 14 Hit final dacieiou on which alternative would be uaed would depend upon the coat and availability of aateriale at the tine of placement aince each ia equivalent in ita effectiveneaa. Under each alternative! the top dreaaing will be weeded with a perrenial rye graaa. Thia will help prevent eroaion and enaure the continued availability of organica in the soil. Studiea dona by Or. E.H. Buckley of the Boyce Thompeon Inatitute indicate thac although roota of the graaa will pick up anall amounta of PCI, the graaa will not tranelocate theee PCBe upward. ' 3. Fencing Fencing.nay be utilised in order to further diacourage public uae of theee araea. At reamant depoait area 3 exiating fencing on adjacent propertiea ay be repaired, replaced or extended aa required in order to liait public acceaa aa ahown on Figure 4.1. Approximately 2,300 linear feet of fencing will be repaired and an additional 1,200 linear feet of new fencing provided. Complete perimeter fencing will be provided at remnant depoait area 3 becauae of ita cloaa proximity to reaidantial area aa ahown on Figure A.l. Area 3 fencing will be approximtely 2,700 linear feet. A. Warning Signe Warning ainga may be poated to explain the reaaona for denial of acceaa and to encourage the public to avoid theaa areaa. There aigna would be poated at 200 ft. intervale along the permetera of both areae 3 and 3 aa delineated in Figure 4.1. The aigna would be 12" by 24" with red lettering on a white background. The following notice will appear: NOTICE KEEP OUT Thia area containa FCB (Polychlorinated biphenyl)contaminated materiale. For information contact: New York State Department of Environmental Coneervation, Albany HONS A - 15 009384 5. Coat Susaaarv Th cost of Cho ratditl action* takan at raanant deposit area* 3 and S ara aiauriiad in eh* following cabl*. TABU II-1 ' COST SUM1ABT Kaananc Dopoait Araa 3 Ramnant Oapoaie ______ Area 3 Araa to be Top Oraaaod Top Dross lag 7 acraa $90,000 4 aero* $50,000 Fencing $30,000 $30,000 Tho coat including miscellaneous itama, continganciaa, anginoaring and adninistradon coses, but excluding ales access and asaaaiane cose* equal* $230,000. 6. Raco--andat iona Sinca evidence axiaca indieationa that reanant areaa 3 and 5 do net pose a huaan health risk and because of Chair isolation, stability and natural inaccessiblity, no action at these sits* ia recoueended at this tine under the rescoped project. A - 16 HONS 009385 III. UPRIVER FLOW EECULAT10H The preeent operating policy for Croat Sacandaga Lake, baead upon original plana developed daring the 1920'a aa approved by Che tben-axiating Hen York State Hater and Power Coaniaaion, provided for a naxiaraa Lake level elevation of 756 ft. during the period Kay 1 to Labor Day each year; the Lake haa been operated under thia conatraint aince 1931. When the Lake ia normally full, the alavation ia 768 ft.; above thia lavel, ahoreline problama occur. The water between the elevation lavela of 756 and 768 ia uaed primarily to regulate river flowa in conjunction with that watar flowing down the main atom upper Hudeon peat the Hadley atreaoi gauge. Until 1977, the deaign flow wea a combined 3000 efa from both the Hudaon and Sacandaga River. Since then, the target flow waa reduced to 2800 cfa, which level waa not achieved until 1980 bacauae of weather conditiona. Civen the current precipitation expeccationa, lower flowa are project for the next three or more yeara. The Hudaon River-Black River Regulating Diatriet eentrola the raleaaea in accordance with an operating regimen, which paya particular attention to down river flowa for flood and other purpoaee. Thia normal regimen ia expected to handle without problem the river flowa during the dredging operation. A - 17 HONS 009386 XV. Ooarational Standarda nd Frocaduraa Mititatinz Maaaurea, Contingency Him and Environaantal KonItprint Frograa A goal of th Hudaon RLvor PCS Raclanation Project is to naxiaixa tho raaoval of PCS--contaainated eediuent fro* tho river ayatra and, at tha aaa tiaa, aininixa potential eoviroiaantal and public haalch problena. In tha developaant of both mitigating naaauraa and contingency plana, a caaaonabla aatinata of poaalbla inpacta nuat ba aatabliahad. Therefora, tha approach that tha Dopartaant of Environaantal Conaarvation haa taken ia firat, identify areaa where problana nay occur; aecond, outline condieiona neceaaary to create there problena; third, develop control aeaaurea to prevent theae problana from occurring and fourth, develop contingency plana ahould thaaa problena acill occur. ' Operational atandarda and procedurea, nitigating neaaurea, and contingency plana have been developed for three areaa, vhich vill be addreaaed individually. Thaaa areaa are: . 1. Dredging, In-River Containaent, and Stabilization 2. Diapoaal 3. Long-tern Storage Thie aectlon will prevent theae conaiderationa aa veil aa a eouprehenaive environaantal nonitoring progran including all areaa of the ecoayaten in tha project area. 1. Dredainr. In-River Containnent and Stabilization Tha Departnent of Rnviroraeeetal Conaarvation will contact, via firat elaaa nail, all reaidenta vboaa property liea contiguoua to riverbank areaa to be dredged two (2) veeka prior to tha initiation of any dredging or conatruction related activity. Furtheraore, tha Departnent vill naintain a photographic A - 18 HONS 009387 doctnentacion of all riverbank araaa which ara Co ha dredged. a. Air Quality Coneldarationa Dredging, in-riwar eontainaanc of hot apota, aa wall aa atabillaatiaa of raananc araaa 3 and 3 have baan aaaaaaad relative to chair inpact on pc> velatiliaation. latiaacaa of PCD loaa potential froa each of chaaa actlvltiea hat baan computed to ba far laaa than tha recoaaaended Rational Inatitiata of Occupational Safety and. Health (HIOSH) 8-hour expoeurt level of 1,0 ug/a3 for worker exposure and, consequently, auch laaa than tha Haw York State Departaant of Health recoaaendation of a 2A-hour axpoeura level of 1.0 ug/u* for raaidant exposure. At the initiation of the cooatruction activities, air saaplea for PCI will be collected on the dredge and analysed for PCS on a daily basis for a aiainua period of two (2) weeks (10 working days). At the teraination of this period aanpla result* trill be evaluated by DEC, EPA sod the Hew York Stste Department of Health and coopered to concentrations predicted by esipirical methods. It should be noted that estimates of exposure for workers engaged in the dredging operation are a maximum of 0.05 ug/m3( thus well below the NZOSH proposed standard of 1.0 ug/3. Subsequent to the data analysisg it is anticipated that the frequency of air sampling at the dredge will be modified to reflect a reduction in the num ber of samples. The present DEC commitment is to temple on e bi-weekly basis throughout tha dradging activity. It should ba raeogniaad that tha air samp ling program muse ba flaxibla, dua to tha profound offoet which motaorology has on disparsion and thua concentrations of PCS in tha air. As prsviously mentioned, air concantrationa of PCI predicted at tha barge are substantially laaa than tha maximum rtcdemanded levels of exposure by NIOSH (0.05 ug/*3 vs. 1.0 ug/m3). Based on comparison tho mieigstion measures which will bo Impleawnced in the event that shoreline concentrations exceed 1.0 ug/3 are: a in HONS 009388 1. Maximise dispersion by maximizing the distance between the transport barf* and nearest residence (considering wind diraction). Wbara feasible, cha cranaport barga (assuming clamshell dradging) will ba leeatad such chat Cha diapacaion, considering wind apaad and diraction, ia a maximum.. In tha-casa of naar ahoca dredging, cha dradga will ba locaead between the ahora and tranaporC barga, assuming aCabla atmospheric conditiona. During cha operation of cha air aaaipling equipment cha alignment of the dredge and barga will ba anch chac Che air samples collected will repreaenc cha worac caaa eondleiona. Thia will inaura chac "worst caaa" concantraciona ae theehoreline can be predicted accurately. Due to diaparaion, FCB eoncencrationa in Cha air at nearby raaidencea will noC exceed lavala ac Cha dredge, therefore, air monitoring will only ba provided ac Cha dredge. 2. Teaiporarily interupc dredging until meteorological conditiona aaaociated with high diaparaion resume. Critical air concantraciona of PCI ara directly aaaociated with meteorological conditiona Which dictate diaparaion. Under the clamshell dradging alternative dredged notarial will ba tranaported by barga to a barge unloading area where the material will be tranaforaed to a alurry and tranaported to the encapaulation aice via pipeline. Eacinatee of PCI volatilisation at thia aita are comparable to thoaa prepared for worker expoaure ac the dredge aita. Air eampling at thia location will only be performed if raaulta from the 10 day intenaiva aampling ac the dredge indicate concantraciona of PCI graatar than 1 ug/m3. Should thia situation occur, a 1 weak (5 working day) intenaiva aampling will ba conducted by DEC at Cha unloading area. Insults of this sampling will ba reviewed by DEC, EPA and NYS Department of Health. As at tha dradga, the probability of air quality problems (graacar chan 1 ug/nO at naaraat raaidanca) ara considered extremely remote. Should air concentration of PCI exceed A - 20 MONS 009369 1 ug/n? at tha unloading araa, uorkara will be required to woar raapiratora. to thia aita la in eloaa proximity to tha ancapaulation aita, tha determination of tho aourea of PCB eoneantraciona in tha air trill ba extremely difficult, conaidering tha otranrhalning influanca of tha ancapaulation aita on tha local air quality. for work at tha remnant dapoaita, ainca no axcavation will ba performed, air * eamplee will ba collactad at aach araa prior to tha initiation of work. Thaaa aamplee will ba eollactad aa part of tha baaalina environment for atudiaa outlined in Appendix A of thia report. Should PCS latrala exceed tha NIOSH propooad atandard of 1.0 ug/1, workara will ba provided with raapiratora. b. Water Supply Conaidaratiooa The areal extant of tha reauapenaion of PCB-contaminated eedimant haa bean documented on ptavioua Hudaon kivar dredging projecta. Thia intonation haa ahown that the dredge pliaae decraaaea to atobiant PCB and netala in water lavela within a maximum diatanca of one nila froa the dredging operation. Tha nearaat water aupply intake ia located in Watarford, (IT, approximately 30 ailaa downatreaa of the propoaed Thoapaon Island Pool dredging. It ahould ba noted that tha tine of travel iron ft. cdvard..to Waterford, in--the flow range of SOOO-BOOO cfa, ia 67-70 houra. Therefore, at average auanar flowa of approximately 3000 cfa, over three daya of retention tin are in the river from the point of dredging to the naareat water aupply intake. It ia not poaeible for material dredged in thia project to remain in ruapenaion for three daya in the Hudaon River. Therefore, dounatream water auppliea will not be affected by the dredging activity. During the aecond year of dredging eeveral of the hot epota propoaed to be dredged, under tha reacoped project are approximately 9 mi lea upatraaa of the A - 21 HONS 009390 Should PCS concentration* ae Waterford exceed Choa* recounended by ebo Hoalch Department (or fiaiabod water, an axiating connection with tho Troy, Raw fork watar aupply will b* utilixad to provide water uncil auch tina aa fiaiabod watar concentration* at Waterford return to acceptable level*. In order to nininixe eny reauapenaion of the river bed aateriel, apecialixed dredging equipment will be utilixed for thia project. Tbie aqulpeent Include* conputar-eontrolled dredge head control equipment aa well aa aealed clanahall bucket* or ahrouded hyraulie euttarhead*. Another eethod to pravent inordinat* downriver tranaport will be to lieit dredging to period* of relatively atable flow. Ro dredging will be done under flood flow condition* when exenaaive Bed inane tranaport nay occur. A threahold river flow ia 20,000 cfa. Baaed on a period of record fron 1931 to 1936 of the Hudaon River at Hechantcville, NT, river flow equal* or exceed* 20,000 cfa approximately AZ of the tin*. 2. Diaooaal a. Air Quality Cona{deration* . Operation of the ait* baa been evaluated with regard to nininixing the volatilixation of PCB. The following deaign and operation procadurea have been developed in accordance with thia goal. ' 1. The ait* ha* been deaigned to incorporate a central dike providing for aegregation of dredged naterial fron the two dredging aeaaon*. Thia deaign nodification ha* the following advantage*: a. Reduce* the expoaed water aurfac* area by approxinately 13 acre*. b. Concentration* of PCB in the dredged naterial, including overcut, are 98 ug/g the firat dredging aeaaon and 33 ug/g the aecond year. Utilixing the two-call design, the noat HONS 009391 a. .concentrated aatarial will ba placed in tha extern nost call, aaxiaizing the diacanca to the nearaat aanaitive receptor. c. Tha two-call design allows for tha placement of a eltjr cowar at an earlier stage than the single call design, further nininixing loaaaa duo to volatilisation. 2. Aa-aaterial ia placed in tha aits, it will''gradually rise above tha water surface until exposed to tha ataoaphera. As Ian interia aaasura to aiaiaixa volatilization loaaaa aa tha uterial bacoaaa exposed, organic aulch will bo applied aa. a volatilisation suppressant. As soon aa tha spoil has developed safficiant bearing capacity, a teaporary cap of 6 inches of soil will ba placed on tha spell. Istiaatas of volatilisation losses froa tha containment sits, as wall ss estiaatas of tha iapact of theae losses on tha nearest residence (aanaitive receptor), have bean prepared, considering tha aoat critical sat of natarological conditions, based on thasa circumstances, studies have predicted that air concentrations of PCB at tha site and nearest receptor would ba wall under the 1 ug/a3 guideline rscoaaanded by the Haw York stats Departae'nt of Healch. Tha astiaataa of PCS volatilisation have been basad on previous dredging studies, volatilisation tank taste on sediaents containing PCB performed by General electric, elutriate tests, liquid film gas transfer theory, and basic ataospharic dispersion aquations. Results of this analysis indicate that non-coaplianca with established air quality criteria is highly iaprobabla, even under tha worst possible natarological conditions, however, operational plana have been developed to control PCB in sir concentrations in tha event that these approach tha recoaaendad Health Department guideline level of 1.0 ug/a3 (24-hour average)a In order to adequately monitor Che air quality, the following air sampling scenario has teen developed: A - 24 HONS 009392 Parameter Micro-Macro logy Locetion containmant site Frequency* continuously PCB containeent sita daily PCI naarast recaptor as direetad*** Although estimates of PCB volatilisation indicate that no problems will ba encountered during tha oparacion of tha containment araaa and weter trtatMnt plant, continfancy plana havo baan davalopad in tha unlikely avant that volatilisation becoewe significant. PCS loss, via volatilisation, is a function of tha concentration of soluble PCB in tha containment site lagoon. Control of volatilisation can ba attained by controlling tha soluble PCB in tha containment area. Basad on past studies and desorption theory, it has bean estimated that-tha soluble PCB in tha containment site would ba in tha range of 10*20 ug/1. Dispersion analyses indicate that PCB volatilisation nay cause air levels of the nearest receptor to approach levels recommended by the Rev York State Department of Health when the soluble PCB in the containment areas is in the range of 28*43 ug/l, in conjunction with critical atmospheric conditions. Therefore, by monitoring soluble PCB in the containment area and the micro-metsrology at Che site, ' critical conditions at tha site can be predicted. for duration of dredging operations up to tima of dewatering of treatment units. **Air sampling for PCB at the nearest sensitive receptor will be performed by DEC a frequency of (l) once per week. It should be recognised that sir eoncentre* tions at the nearest receptor will be a function of atmospheric stability conditions. Wind speed end direction can effect the location and dispersion of tha plume. Therefore, the location and frequency of this remote sampling must be maintained e flexible program and incorporate the miero-mettorology of the aito. Possibla sampling locations will be at tha nearest reesptor in any single wind direction. A continuous record of meteorology near the site will initiate in 1981 and continue throughout the duration of the projeee. At least s full pear of data will be available from this station prior to dredging. This data will be utilised by DEC in the placement of the remote air sampling equipment. A - 25 HONS 009393 In eh* mliktljr event that anaaurabla quant i t iea of PCS and/or heavy Matale an ancountarad in tha wacar of tha Monitoring valla, tha valla of local raaldanta within 100 a of tha aita boundary vill ba aanplad for PCS and baavy aatala. Should tha raaulta of tha analyaaa indicate that ehaaa valla eoataln PCS, NYSDEC would, aa an interim aaaaura, iaawdiataly aupply bottlad drinking vatar and carbon flltara for faucata to houaaholda within 100 aatara of aita boundary- Alao, an anginaaring analyaia vill ba conduccad to *---------- r tha aarial extant and magnitude of tha problem and to develop and iaplament remedial maaaurea (a.g. public vatar aupply). 3. Long-tana Storaga Long-tan aaintananca and monitoring programa vill ba inatitutad at tha containaaant aita, remnant dapoaita and at any araaa aalectad for in-rivor cemtainmane for a minimum pariod of 30 yaara. Pariodic raviava of tha program by NYSDEC, HYSDOH and 0SEPA vill raault in modifieationa to tha original prograai, in accordanca with tha output of tha Monitoring program. In accordanca with tba Section 116 (a) of tha 1980 Claan Water Act Amendmanta, tha goal of tha containaient aita Monitoring prograM ia to danonatrata "tha feaaibility of indafinita a torage in aCShre landfilla of toxic aubatancaa." A Federal panic for tha aita vill ba required purauanc to tha Toxic Subatanea'Control Act (TSCA). A State pamit ia alao raquired for tha conacruccion and oparacion of a aolid waaca diapoaal facility, loch of tha aforaaantionad pemita vill contain raquiremanta for long-tan Monitoring. Tha atata of Haw York ia lagally bound to eoMply with tha raquircuanta of ehaaa panlea and ia conitted to do auch. Paraaatara idiich have bean identified for the long-can Monitoring/ naintananca prograa ara: 1. Laachata Diacharga M0NS 009394 column of 0.10 ug/l which ia about a 20 percent increase over the background level*. The addition of filtration and activated carbon adaorption systems ha* bean exjoined to further poliah the treataent plant effluent. The capital coat for thia inatallation la approximately Oil million and ia, therefore, not considered. an economically viable opcion. Soluble PCS in the range of 10-20 ug/l may be anticipated with the dredging operation. If couditiona of effluent auapended aolida exceed permit limit* at the water treataent plant, polymer addition haa been provided at the inlet of the roughing and atorage pond. Thia will maxiaixe tattling and reduce effluent auapended aolida, hence reducing effluent PCS. The water treatment plant ia deaignad to remove aolida. Soluble PCI and aoluble natal* will not be removed by thia ay*tern. ii. Groundwater Groundwater will be monitored for PCB and heavy natal* aa well aa water aurface elevation at the containment aite on a quarterly baaia (every 3 month*) or in accordance with the proviaiona of federal and atate ait* permit*, whichever i* nor* atringent. Groundwater monitoring well* have been provided around the containment rite perimeter both hydraulically upgradient and downgradient of the ait*. The aoil* of the ait* have a permeability of approximately 2.b x 10~7 cm/aec and are compoaed primarily of Kingsbury ailty clay along with Covington ailty clay loam and Vergenne* ailty clay loam. Theoretical migration of water from the ait* i* eatimated to occur at the rate of 8.0 x 10-4 ft. per day. At thia rate, it could taka 600 year* for leachate to travel a diatanc* of 200 ft. to the property line. PCB and heavjr metals would adaorb to soils at the site and not migrate with this water. Their movesmnt would be up to 10,000 times slower than that of-water. - 07 HONS 009395 to determine any gas generation rates. b. Thraahold for Cone infancy Action - If ambient air levels of gases at tho aito exceed appicable standards, tho contingency action will bo initiated. c. Continiowcr Action - Valvti at gas vonts will bo closed. Cases will bo drawn from tho containment cells through tho vented gea treatment system. 4. Air Quality PCI in gases that say bo generated within tho containment cells vill bo vented through tho gas collection system. a. Site Operating Procedures - Valves on gas vents will bo normally open. PCB contained within gases that may bo generated will bo vented to tho atmosphere. Site air monitoring and periodic sampling at gas vent pipes will be carried out to determine the presence of PCB tevels in gas that may be vented. b. Threshold for Contingency Action * Baseline monitoring studies (out* lined in Appendix A of this report) provide for collection of air quality data at the site prior to construction. As&ient air concen* trations of PCB on the boundary line of the site after the site is closed vill be compared to annual average concentrations prior to site operation* This data vill be provided BPA and to the Bow York State Department of Health for assessment of possible public health concerns. Six (6) air samples vill be taken by DEC the first year after site closure, during stable atmospheric conditions. Sampling frequency may be modified efter review of this data by NYSDOH. c. Contingency Action - Valves st gas vents vill be closed. PCB* contaminated gesee will be drawn from tha containment cells through the vented gas treatment system. MONS 009396 2. Groundwater 3. Call Caa Generation 4. Air quality 3. Covar Integrity 6. Covar Vegatation 7. Saeurity 8. Drainage Thaaa itm ara diecuaeed individually balow: 1. Leachate Diacharga The call laachaca collection ayetea ia deacribad in Chapter Six of the Contaioaent Site Deaign Report, September 1980. Tha deaign laachata dieeharge ia divided in two phaaaa: _ _ * ehort-tera dewatering of dredged Material * long-ten percolation through the clay cap Eatiaated quant itiea in theta phataa are: Water Diacharga Average PCS Kara of PCS Million Gallons Concentration* Discharged Short-tara S3 over an eatiaated 6.3 ug/l 5 lba over 2 2 yeera yeara at 10 ug/l Long-ten 1.3 per year 6.3 ug/l 0.1 lbs par yaar at 10 ug/l Dilution at river low flowa of 3000 efs ara l:30,000 and 1:600,000 for tha above flow ratea. At the low flow ratea and eaaa of FCB involved, it ia not anticipated that tha direct dieeharge will have any appreciable effecca. a. Site Operating Procadurea - Control valvea at the leachate ayatea collector walla will be open. Laachata generated in thia containaant cell will diacharga by gravity to a leachate atorage tank and then to MONS 009397 A - 29 I, Cover Vetetstion The design of the containment ait* ia auch thac nininum maintenance would ba required aftar an initial stabilisation period, but this minimus would bo aaaantial to anaura tha integrity of tha aita. Maintenance of a haalth graaa lagoon cover will ba provided to control aurfaca oroaion and pravant trao growth. FCB aigration upward through tha cap will ba nonitorad by pariodic aaapling of covar vegetation. By providing a gaa collection and venting ayataa (rafaranca Daaign Report, MPI, 1980) tha poeaibility of upward aigration of PCI la reaote. Tha uaa of planta to aonltor lew level exposure to PCB haa bean demonstrated by atudiea carried out by tha Boyce Thoapaon Plane Kaaaarch Inatituta of Cornell Oniveraiey. a. Site Operating Procedurea - Surface vegetation will ba aonieorad for PCB on an annual baaia. b. Threohold for Contingency Action - Measurement of PCB in vegetation above FDA liaiea. c. Contingency Action - Should threahold concentrationa ba aeaaured, a detailed atudy will ba conducted to determine the concentration profile of PCB on tha aita. A layer of highly organic aatarial will ba placed on thoaa araaa and a detailed inveaeigaeion will ba inetltuted to determina tha aourea of the problem. 7. Security a. Site Operating Procaduraa - Security of tha aita will ba maintained by periodic patrol/inspection by Environmental Conservation Officera. b. Threahold for Contingency Action - Should it become apparent that vandalism and cresspaaaing are occuring, contingency actiona will ba HONS 009398 FCB and heavy metals. Also, waCtr elevation in aach wall will ba noead on a monthly basis Co assass eha groundwater gradient. A wall log book will ba maintained for aaeh of cha six walls. A formal raviaw of wall log data by NTS DEC, IfYSDOH and U$E?A will ba conduce ad. Sampling frequencies may ba modified as a result of this action. b. 'Threshold for Contengency Action - Monitoring walls will ba installad and sampled during tha construction phasa of cha encapsulation site. If potc-consCruet ion concentrations of ambient groundwater exceed levels measured prior to dredging, contingency plans will ba initiated. c. Contingency Action - Initially all walls utilised for potable water supply within 100 m of tha site boundary will ba sampled for PCB and heavy metals. As an interim measure provisions for individual activated carbon filtration units and bottled or tanked water will ba made in tha event that sampling indicates potable water supply contamination attributable to tha PCB encapsulation site. Also, an engineering study will ba conducted to document tha areal extant and magnitude of tha problem and to develop and implement long term remedial measures (e.g. public water supply). 3. Call Cas Caneration The potential for gas generation in the containment cells is minimal because of the low overall level of organic material present in the contained material. A gas collection system is provided, however, in order to avoid any possible gas accusiuiation and resultant uplift and rupture of the eover system. a. Site Operating Procedures - Valves on gas vents will ba normally open. Any gas generated will be vented to the atmosphere. Site air monitoring and periodic sampling at gas vent pipes will be carried out HONS 009399 4. Environaental Monitoring Protraa Introduce ion Organixation Work Plant A. Air and Plant Sampling Study and Related Site 10_Monitoring B. Coring Fathomtry and Praciaioa Dredging Monitoring C. Sediaent and Hater Traneport of PCS and Hater Supply Monitoring D. Hear Dredge Hater Stapling Plan E. Ketlanda Mapping, Photography and Changee P. Monitor Sediaent Iroaion and Burial G. Piah Saapling Study H. Macroinvareibrate Saapling Study J. Study of PCS Releaae froa Hadaon River Sediaenta PCI Saapling Analyeia and Data Plow Sn--ary Quality Control and Aaaurance HONS 009400 }. Cover Integrity The cmulnane call cap ijritaa conaiaca of thraa layers of selected aaterial---18 in. of highly iaperneabls clay, 8 in. of sand and gravel drainage layer, and a Cop layer of 10 in. of top dreaaing notarial for eetabliehaanc of tnrf. The cover will be graded eo prevent ponding of water and aaxiaize arfaca runoff and niniaize the potential for eroaion. Detail* of the eap and the ayetea of paved aurfaea water collection ditchea are given in Chapter of the Cootaiiment Site Deaign beport, Septaaber, 1980. ' a. Site Operating Frocedurea - All site graaaed areaa, including the con- tainaenC cell capa, will be Bowed periodically during the growing aeaaon to prevent growth of woody planta, permit inspection of eap integrity, and to facilitate inapection and repair, fertilisation and reseeding of areaa will taka place as necessary. b. Threshold for Contingency Action - Any scour areas, cracks, aniaal burrows or settlcasnt areas discovered in the periodic inspections will be noted, supped and narked. Repairs will be scheduled within 30 days and prior to onset of the winter season. c. Contingency Action - Repair of scour, cracks and settleaent areas wilt be aade with top dressing or clay aaterials as appropriate. All disturbed areas will be fertilized, seeded and aulched. All repairs will be logged, napped and be given special inspections until fully reestablished with protective turf. Photographic and other records will be kept as part of the sice operating records. Trapping and relocation of burrowing animals will be carried out as necessary. A - 33 HONS 009401 etnauriaad Mapling plan (bowing aanple aadia, laboratoriee and data aanaganant and quality control. Stodiaa on thia project'* a(facta bayond 5 yaara, ara conaidarad long-tarn nonitoring, not to ba funded by tha EPA grant. HONS 009402 initiated. e. Contingency Action - Daily patrol/inspect ion will ba requested from tha N.Y. State Police in conjunction the 8.C.O. patrol*. Repairs to facility froa vandalism will be repaired by the Department. S. Drainage The eite drainage system will be inspected concurrently with the sampling of the monitoring veils. a. Site Operating Procedures - Drainage system will be maintained in operable condition. b. Threshold for Contingency Action - Vegetative growth in drainage channel, debris impeding the flow or breakdown of channel tinea will necessitate contingency plans. c. Contingency Action - Channels will oe cleared of debris or vegetation as required to maintain hydraulic capacity. The use of herbicides nay be required to control vegetation. Repairs to channel lines will be the responsibility of DEC. HONS 009403 Jt - 1* A. Atr and Plant Splim Study and Related Site 10 Monitoring Introduction res volatilisation incraaaaa with cha PCS concancracion in cha --Hninr or vatar, with Cha eurbulanca level in Cha vacar and with tha tanparatura. Dispersion and incraaaad wind spaed tanda to laaaan cha air concantration of PCS' whila. increasing total emissions. Tha aonitoring plan la baaad on tha probability of having naaaurabla environmental affacta baaad on pravioua study data and calculationa. A probability Cabla on likaly PCS air aourcaa followa. Savaral itana need explanation. Thera ara 8 daaa froa Troy to Ft. Edward. Tha highest PCS water concentrations ara likaly to be at tha Thowpaon Island, Lock 6 and Lock 5 daau. Two studios of gas transfer ware aada at tha Lock 6 daai by UgGS, indicating gas transfer rates 10 to 20 times higher than for typical pooled river areas. Calculations by Malcolm Pirnie, Inc. indicated chat air amissions from barges or dradgas would be insignificant, <.05 ug/m3 peg. Due to low turbulence conditions in tha quiet river water areas, it is expected that air concentrations will be lass chan 0.03 ug/m3. Prom tha Malcolm Pirnia, Inc. A/7/81 analysis, under worst condition of E stability tha Site 10 air concancracion would be 0.J g/-3 while at tha nearest house it would be 0.2 ug/m3. Thus, air awn i Coring for PCS over a central area in tha lagoon system, surrounded by water and downwind of tha influent pipe turbulent rone, would give higher PCS levels than at tha houses 220-S00m away. Tha primary air and plant monitoring will ba carried out by the Boyes Thompson Institute of Cornell University. However, tha NYSDEC, Bureau of Hater Research will conduct tha sampling on Sits 10 during dredging whila cha Division of Air Resources will analyze tha meterology and dispersion data. A description of the progam and Boyce Thompson Institute's 1981 contract proposal follows. HONS 009404 Introduction Over thu past several jutri thara has boon several Billion dollars of nitarch. wonicoring and engineering studios ralating to PCS in tha Hudson River that wars authorised by tha PCS Settlement Advisory Coanittee. Tha purpoaa of this Monitoring and laaaarch Flan (MRP) ia to aaasura tha trua affact of tha raaadial naaauraa on tha environment. Thus tha MRP ia dasignad it to docvaunt how wall tha project achiavaa its projected benefits and prevents ' I or causes any secondary adverse iapacta. Tha area covered includes both the upper Hudson (Ft. Edward to Troy) and lower Hudson (Troy to Hew York City). Sons studies, such as fish and water aonitoring, are designed for a S year duration to show true dredging affects. Others are dasignad for the 1-2 yrs iansdlately surrounding tha dredging event. Both the 1-2 year studies and tha 5 year studies are needed to show the effects of tha prejaet on the anvironnant. Longer tern studies ainilar to tha current progran will be aaintainad as appropriate. MRP Developnent and Managanent The MRP was developed .by MTSDEC staff along with tha scientific subcoauittaa of tha FCB Sattlanent Advisory Cosuittaa in Novenber 1980. This progran will be carried out by the MTSDEC, in consultation with the PCR Sattlanent Advisory Coauittee, the MTS Departnent of Health and EFA Region II. Organisation and Index On tha following table tha various aonitoring and research tasks are indexed. For each task there follows a more detailed description of tha work for that task. Those budget itens listed under the Step l Grant are for pre-dredging monitoring. Then there follows detailed workplans, a MOWS 009405 3. Alto, air and plant aaaplaa will ba takan in tha tuiemsr and (all in eba vicinity of Lock 6 dan to aaaaaa tha loaa of PCS bp rlvar volatilisation. Ihia ia to aaaura that PCB air concantrationa at tha dan aita do not exceed 1 ug/a3 during dredging and to document any incraaaa in PCS in eropa along tha rivar naar tha data. A. Air-and plant aaaplaa will ba takan owar raanant dapoaita 3, 4 and 3 which repreeont low level PCS aourcaa. For paragrapha 3 and 4 plant aaaplaa will ba analysad by Kaltach and air aaaplaa by Cornall Dniveraity. A Raltach aapla load of 200 to 230 aaaplaa par yaar ara plannad. Tha purpoaa of tha raanant dapoait aaapling ia to aaaaaa if air concantrationa eould avar ba axpactad to axeaad 1 ug/a3. 3. Grata aaaplaa will ba takan froa dradging natarial aitaa at Buoy 212, SA 13 and tha naw Moreau landfill to detaraina tha PCB lava! in typical grata grown on a capped, diapoaal aita. 19>2-43 Putina Dradaina Plant and Air Related Monitoring Paragrapha l, 2 and 3 above will ba repeated during tha dredging yeara. Tha farm plot* in paragraph l may ba reduced from 4 to 2. Forage crop tempting near Site 10 will incraaaa to document any contaminated araaa while sampling in paragrapha 1, 4 and 3 above will deereaee. It ia not axpactad that planta more than 700 matara from Site 10 will ba affected. Approximately 230 plant aamplaa for Baltech, par yaar ara plannad. Tha waathar atation will ba moved co Site 10 and a continuous air monitoring atation aatabliahed where high PCB concantrationa are expected. Thera will be continuoua air tempting during the dredging aeaaon. A new eample will ba collected every 24 houra. Other aamplere, mobile aamplera. will ba moved upwind, downwind or to nearby houaaa, aa needed, to verify diaparaion predictiona in periodic atudiaa. The DEC lab will have tha capability of HONS 009406 i' toiwt mi Nm Ma 4~l (Mfck, M4v Tnk Ctriai, (atlMMlry li 4r4|<M aMliwltf lailaalal Mill Tatal 9 400,000 laMMCk, kMltir m4Imm irniM . mi btrlal -- M6, mi ! 1kMfM (MlltaU Air NmIimlag far Kl mi HMtk kraala 10,000 M6, kwiM af Hitir lH<r(k ratara IIm, mi mm 4fM| MaiiMlai M.ON* BCC, Baraaa af tfatac Miitcck Ills It graaal Mlr mi iMflUl mi mcm klM At,Ott i MC, kwiM ( VMlf aaaarab. ImhmI taahalaal Mkiun mi mi pk*(|f*pk u,! BU( laraaa ( tour taMMCki Irajtil Likariiwy far mA|mm( mur mi air aaalyaaa MC, kMM < U*. tfIMt Im, A. Uylaw Ila* Kl Uaali )M,N0. 990,000 * HI >!< ( Ullltk/MC A. Ua|alin aacnlwariakrata craaOa HONS 0 0 9 4 0 7 HM, Alkuy, 1. Haar liM|i Maralatar* lafciata craala Vatar mi idlMii Kl # fart, w(r wffliai 90,000 290,000 k|K IMfMI iMtllMtf! MIC, kr<M if Mitir MM*rk mi MjrM Iknyiw lAMitnl* laiv. af Ni<kl|M, HmI Kl tcaala, Air 9Cl iraali Uatlaala aaffU|, fkala|(*rkr aal (kaa|ii ( Kl 4mch 1 araalaa In* kaiiaa MkiMMii al *>i*| A90,000 laaluOaJ lava 90,000 Tla rraaa 1 1/1 fra, ItOI- 2. 12 * i t fra, IHM) 9 yn I M 1 l/t fra. IfII, 1902-09 9 fra i 2 fra, 19029 * 9 fra 1 fra, INI, ItOi-O) I fta, 1901-02 The DSC laboratory ia anticipating about 200 Sita 10 water PCI analyaaa during tho dredging acaeon. Heavy netala will be analyzed on Site 10 return flow samples aa preacribod ia the alee diecharge permit. In sumaary, all data on the sediment, water, air and weather conditiona fram Sita 10 will be entered daily into the project data ayatam. Thia data will be uaed for real tine operational eontrola of the ayatam to aaaura that KB aacapa from the Site will be minimiaed and alwaya laaa than the eatabliahed atandarda. 1M4 Monitoring of Air and Planta After Dredging and Site 10 Capping It ia anticipated that plant and air campling around Site 10 and lock 6 dam would be continued for one year after dredging ia completed to confirm that plant and air KB levela return to pre-project levela. Caa collection will be provided for the containment cite aa deaeribed earlier. The rate of gaa flow will be recorded continuouely and PCS concentration will be naaaured aa dictated by the NTS Air Quality permit for the aite. It ia anticipated that the flow of the gee and ita PCS concentration will be low enough to permit diecharge to the atmoaphere. If thia is not the case, the gaa will be created thru an activated carbon column prior to diecharge. Approximately 5 graaa saa^les from the alee 10 cap will be analyzed for PCB for each of tha 2 years after sice closure. Savcral graaa saa^lea for KB will also be taken from remnant deposit areas 3 and S. HONS 009408 1911 - lackaround Monitoring 1. (laea thara it, nrtantl/, no accaaa available Co Sica 10 proparty for editoring itodin, background data will be eollaeCad at artaa bordaring the site. Four fans around the Sita 10 have bean aalactad for plane - air mattering plota. Oa thaaa four surrounding tana, thara will ba experimental plant plots and one air aanpllag atat ion. This ssapling will docmanc background air PCS values and plane PCS concentrations for a variety of species bafora dredging. There will ba a waathar station continuously gathering data for wind speed and direction (direction fluctuation 6), ralativa timidity, solar radiation, air tanperature, and precipitation. Various plant apeclas will ba analysed for PCI and bi-weekly air samples for PCI will ba corralaead with the plane and waathar daea. The awaar and fall 1981 waathar data near gite 10 will ba correlated with the Albany and Glana Falla air daea. Predications will ba wade of worst casajaateorologicai conditions for tba 1902 or 1903 dredging season. Frost this data natrix of contaminated planes, background plants, waathar data and PCI anise ion as C inates frm Sits 10, Boyca Thomson will calculate probable land areas where plant PCI levels will ba iasreased. This data will ba utilised to determine the aerial extant. 3. In addition, agricultural crops and vagatation, in a A nils square area cantering on Site 10, will ba aanpia* twice on a A X 4 grid pattern during the nmr and fall, to detention background levels for conpariaon with PCI levels during and after dredging operations. The samples will be analysed for PCI by alteeh Laboratory. Aerial photographs of the crops will be periodically taken. ' MONS 009409 41 00*410 B. Coring, rth--try. and Preciaion Pcadaiftt Monitoring NYSDEC, Buruu of tfator Rootarch 4 Hnlcoli >iriao lac. Introduction Tho propoaad prograa will naaauce th efficiency of renewal V contaainatad layar and-aaaa of PCS raaovad, aaaaura changea in hot and gaoaMtry and daptha of drtdging cut a, and iaprowa tha afflclar <1 rad,inf procasa aa it procadaa. Corini and Fathoaatry Coring will taka placa on a 100 ft. grid in and aaar hot t will ganarata 1 cora/10,000 aq. ft. hcfora dredging and l eora/ dredging. With four core aactiona before dredging and two afti apota, thia will generate 3,000 core aactiona for analyaia for or firat dredging aeaaon. The coring will be done aufficient* operation in a given hot apot to inaure that accurate hot ago to dirccc the dredging operation. Detailed location wapa of will be prepared. In initial hot apota deaignated for detailed atudy, co planned to taeaaure the preciae peccant PCS actually renewed The dredging overlapa and cucting pattema would be and tha atudy repeated to get the auutinun econonic effieie Thua about 5,000 core aactiona era planned for analytic f aeaaon (Tbonpaon Ialand Pool). To do thia voluaw of aed: effective and tinely analytical technique it required. Studiea at NTS Department of Health, Sadiological ! NYSDEC of DEC and Dr. Sapp of Laaont Doherty Geological a good correlation between PCS, C(137 end pb for the eta, che correlation coefficient vartea froe 0.4 analysing 250 atr eaaplee ovar tha dredging Mason with a 2 day curn-arotmd Ciaa. Dradging lagoon wacar taaparatura and affluent PCB will ba aaasurad daily. If PCI air eoneancrationa ara likaly to approach 1 ug/a3, dradging will ba atoppad and activatad carbon addad to tha lagoon watar. Fraquant updated pradictiona of this avant will ba nada on tha basis of worst ease aspactad data. Sadiaant coring and analysis will giva tha sadiaant PCS lavals bafora ebay ara dradgad. le is anticipated that up to 5,000 saaples will ba analyzad par dradging yaar. whan pose dradging aaapling is also includad. Tha dradging lagoon Influanc percent aolida and flow will ba aaaaurad by a recording aatar on tha pipeline. By Manuring tha sadiaant reaoved fron the river, the nature of the sad inane entering the lagoon can ba calculated. This will ba confined by periodic aaapling studies conducted on tha lagoon influent pipe discharge and on tha puapout station sadiaant Mixtures. This approach has bean selected because aaapling of a dradging discharge pipe can ba a difficult and iapracise operation. The final lagoon effluent PCB will also ba aonitored daily via autoaatic coapoaiting saaplars operating on a 24-hour cycle. A special SMpler to ainiaixa volatilisation losses will ba used. Sines tha lagoon syataa ratantion tiM is savaral weeks, soluble PCB will ba Masured less frequently, typically once or twice par weak. The effluent fron tha eain containaent site will also ba saaplad continuously as prescribed in tha site discharge perait. During tha wans aonths of July and August the analysis of tha containaant site effluent could approach a daily cycle. Honitoring of the containMnt site syataa during tha cooler, less critical Moths will provide Mre preciM parasatars for Mnitoring and operations. MQNS 009411 Addition*! Work. It i* anticipated that a masher of additional uses for th* coring, fathoaetry and praciaion ranging aquipaent will ba found during tha projace. Included are: (1) pracoring work to confine PCS hoc spot boundairea; (2) probing of sadislant daptha and rock outcrop* aapecially in th* lock i to lock S pool; (3) surveying dredging boundry line* around uatlanda; (4) noting change* in river bad gaoaetry after flood*, ate. MOhS 009412 Probability Hi--ary lalativa to Plant and Air Monitoring Crop* axeead .2 ppn Air excaada 1.0 u|/a> On Sita 10 PDA N HA N INN ~700n Sita 10 700a llt 10 PDA PDA N LN NNN INI III lock > Dan Araa N--iant Depoaita 3 and j PDA PDA L U NL NA NA N NN N N NI Crop* exceed .2 ppn Air axceeda 1.0 ug/a* Hot Hpota in Kivar -700H Naauiant Dapoaita lariaa 4 Dredgea iD A P A L - L- N araa i araa 3 KA HA NA NNI III I-Alaoat Inpoaaibla, N*Not likaly, L-Likely, V-Very likely1, NA-Not applicable or no cropa, P>praaant conditiona D* During Dredging, A'After Sita 10 and raauiant capping. HONS 0 0 9 4 1 3 United States Department of the Interior ' GEOLOGICA I- .SUHVKY waur resources division P.0. BOX 744 ALBANY, NEW YORK 12201 ALBANY SOBDISYBXCI October 24, 1980 T. J. Tofflauira Now York Stats Dapartaant of . Eavironneacnl Conservation $ 50 Wolf load Albany, Now York 12255 .> Doar Dr, Tofflaalra: Tbo followlac estimate la aado for tha nunbar of Hudson Alvar samples that will bo cakaa for ?CB analysis In IT81. Station Location Hunbar of Sanolsa Clans falls BO|ars Xaland Cbannal logsrs Island Canal Schuylarrilla Stillwater Waterford ) 23-50 23-50 10-13 23-30 23-30 latuary___________________________________________ 23__________ . local approximately 130 Tan sanplas will bo takan at Stlllvatar for coaparison of analytical raaulcs Iron tha USCS and S.Y. Department of Haalth laborstorlas. In addition, a apodal study that lndudas a total of 23 sanplas at Rogers Island, Bakars falls and 2 tag-line transacts batwaan thaaa stations will ba conducted In tha fall of 1980, Dally sadlawnt collactloas will contlnua at SClllwacar and Watarford. for tha Dlatricc Chlaf: . Vary truly yours, RAS/skw Roy A. Schroadsr llydrologlsc HONS 009414 leg Cfl37 or'H. The data table follows. It is iaportant to note that one Pb will ba done by x-ray flourescsnce and C,137 by a dual channel genea ray counter with alithiua-gensanian detector. Both instruaants cen enalyae seaples in leas than 30 oin. C$137 cm froa atoaic boab fallout about the saaa tiae period as the C.E. PCI dischargee. The upper Budaon giver lead caaa priaarily froa one discharger, Hercules Cheaical just upatreaa of the C.I. PCS discharge. Pathoaetry aquipaent will also be used priaarily to aonitor the depth of the dredging cuts reaowed in the hot spots, it is planned that transacts across all hot spot areas will be done on 30 sq.ft, intervals before and, iaaediacely, after dredging. This will necessitate about 250 transects in tha Thoapson Island Pool. Electronic ranging aquipaent such as the Hotorola Mini-ganger with a Hewlett Packard aini-ccaputer will be used. This aquipaent aakes possible autoaatic recording and plotting of exact river locations and depths. Precision Dredging Monitoring Precision dredging aonitoring and control are essential to provide a naximas removal of PCS-contaainated aediaent with a ainiaua of losses. Each dredge will be equipped with electronic ranging to record the dredge head aovaaents. For tha claashell dredge the HT antenna will be located on top of the dredge booa directly over the buckec. The x and y grid coordinates for each bucket grab will be recorded on tape. There will also be a CHI screen tied to the systea on each dredge cab. There will be a preplanned optiaua claashell biting pattern recorded on tape. Thus, displayed for the dredge operator will be a grid pattern of dots where each claashell bits should be taken and a circle indicating the instantaneous location of the bucket relative to the ideal pattern. Each tine a claashell bite is nade, an x will be entered on the screen st the actual location of the bite. HONS 009415 EFFECTIVENESS OF DREDGING IN LOWERING PCS CONCENTRATIONS IN THE HUDSON RIVER pnnxi.rM PCS'* were discharged Iron 2 industrial outfalls on tha upper Hudson Rivar near Ft. Edward. Naw York free about 19S0 to 1976. Subsequent erosion and transport downstream has resulted in serious contamination of bath tha upper river system and the estuary. Although contaminant concentrations of - the river remain much higher than those of tha estuary, the major economic impact is nanifested in loss of the commercial fishing industry in tha estuary. The towns of Waterford (upper river) and Poughkeepsie (estuary) obtain their public water supplies from the Hudson River. Treatment is required to ensure PCB levels in drinking water are below the limit of 0.1 ug/L set by the New York State Health Department. Hew York City has expressed interest at various times in the past in the use of Hudson River water for its water supply. The town of Behtlehem in the Albany area has expressed a similar interest. Hence, PCS levels in the Hudson River system are of interest to these comsunities as well as to those already using the resource. ' The New York State Department of Environmental Conservation, as the lead agency in attempts to clean up the river, has received 26.7 million dollars to renova contaminated sediments (so-eslled 'hot spots') form the upper rivar. Dredging will commence in 1982. In addition. General Electric will remove PCB contaminated material from 7 landfills in the Upper Hudson basin. And finally, an expressed desire by Niagara Mohawk to rebuild a hydroelectric plant on the rivar may result in financial commitments by the utility to remove remnant deposits stored on the banks of the river. HONS 009616 C. Sadiaant nd Water Transport of FC dn Water Supply Monitoring BSCS l BTSDEC. Bureau of Wtr Research Introduction Thn aain rivtr water (sapling over tha 5 yr period i included in tho atcachod USGS proposal. In addicion, USCS aaintaina daily flow |au|in| at a niabar of_points and auapandad sediaent aeasureaents at 2 points along the Hudson River. R - JQ HONS 009417 APP!(QACH 1. Concentrations during. and after dredging will be compered with bastlina concentrations (FY 77-82) undar comparabla flow conditions. Discharge will ba obtained from ostablishad water-stage recorders at Ft. Edward, Stillwater, and Waterford and a wire-weight gage at Schuylerville. About lSO.samplasfrora 5 stations, one of,,which is a background station, on the upper Hudaon and 25 samples from 5 stations in the estuary will be analysed for total PCS concentration. About IS samples will also be analyzed for dissolved PCB's to confirm earlier results which showed PCB's to be dissolved at low flow and attached to suspended material at high flow. 2. PCS concentration has been found to be Inversely proportional to discharge (except at very high flow) at 4 stations in the upper Hudson. The regression relationship between these variables will be calculated at each station with slope of the line giving daily transport past each station. The station at Schuylerville will be particularly important because it is immediately downstream from much of the most highly contaminated sediments and should therefore show the most obvious drop in daily PCB load as dredging commences A minor but significant portion of PCB's transportsd annually are delivered by resuspension of substantial quantities of bottom material during flood discharges which typically accompany the spring snowmelt. The amount transported will be obtained from PCB concentration multiplied by discharge with daily suspended sediment data (at Stillwater and Waterford) used to estimate 0CB concentrations during periods of a flood event for which PCB data are not available. HONS 009418 ]. The approach appliad in item 12 above at the lowermost riverine station, Waterford, will be assumed to give the PCB load to the estuary. In addition, PCB concentration will be measured 5 times a year (mostly during the summer) at 5 already established stations in the estuary to document the downstream decrease in PCB levels. United States Department of the Interior GEOLOGICAL SURVEY WATER RESOURCES DIVISION P.0. BOX 7kk ALBANY, NEW YORK 12201 ALBANY SUBOI STRICT Hareh 6, 1981 Italo Card eh Buraau of Water Research 50 Wolf Road Albany, New York 12233 Dear Nr. Carelch: The enclosed document Is a copy of a project proposal being submitted by this office to our Headquarters for their evaluation. If approved, the study would extend cooperative funding for Investigation of PCB's in the Hudson River through the 1985 water-year with a final summary report to be prepared in 19. The proposal should be considered a working document at this time. Perhaps we can have a meeting soon to discuss any changes and recommendations you have. For the District Chief: Vei^ntruly yours RAS/skw Enclosure MONS 009419 Thr is * no<*d Co know, how affective dredging will b* in lowering fC9. v, ' concentrations'of the Hudson River. .Pre-drcdging beseline information on ' i 'I PCB concentrations has boan obtained sinca 197? under a project (NY 7S-04SI fundad cooperatively by the Maw xork State Department of Environmental Conservation and the U.S. Geological Survay. This proposal requests an extension of that study with tha objective of determining tha effectiveness of claan-up afforts. OBJECTIVES 1. To determine whathac clean-up efforts lower concentrations of PCB's in tha Hudson River. " 3. To determine relative importance of various reaches of tha tipper Hudson in contributing PCB's to the river water. ' 3. To estimate loads of PCB's delivered by the upper Hudson to the estuarine Hudson. 4. To monitor affects on municipal water supplies during dredging. 5. To determine changes in isomeric composition of PCB's in river water near the source of tha original discharge. S. To maintain an appropriate quality control program. HONS 009420 A- g. Wetlands Mapping, Photography and Channes BT5PEC Various Unto and Boyce Thompson Institute Introduction Whom possible, the reduced scope hoc spot dredging project hes been designed to avoid dredging ell wetlands rated as valuable. Nevertheless, a snail portion of aosse of the wetlands adjacent to deep water hot spots and subjece to scour will be dredged. A cooperative progran with the Boyce Thoapson Institute and DEC staff is planned to nap and delineate the exact boundr7 between the deep hot spots and wetlands to be dredged baaed on water depths and plant specias observed. DEC'S fathooetry and electronic ranging egvipnent will be used for this purpose. Vegetation in Che hot spot wetlands below lock 6 has bean saapled and found to be contaainated with FCbs. Aerial photographs can be taken just before the dredging and a pear after the dredging to allow an accurate coaparison of any changes or loss of wetlands due to the dredging. HONS 009422 4. water from the raw-water intake at the Waterford Municipal tutor Treatment Plant will bo analyzed for PCS concentration about 10 times a year, both during and after dredging. Sampling at the plant will coincide with sampling of the river from the Waterford bridge. Dual sampling will answer objections raised by the Regional office in 1978 when it was concluded that concentration from the bridge is identical to concentration at the intake pipe although no samples were actually takan at the pipe. 5. Results of a special study conducted last fall indicate PCB's change isomeric composition to a less volatile mixture (personal communication. L. Lowe) within the first few miles below their original source. The project chief will travel to the Central Lab in Atlanta to personally check previously obtained chromatograms for differences in isomeric composition. In addition, previously reported zero values from the background station at Glens rails and treated water from the Waterford public water supply will be checked for low levels of PCB's, These efforts will require consultation with a specialist in the Central Lab. 6. About 10 percent of samples sent to the Central Lab will be duplicates. Ten splits from Stillwater will be analyzed by the New York State Department of Health Lab. Standards of PCB in hexane and in water will be analyzed by both labs on a periodic basis, 3 or 4 times a year. REPORT PLANS Results will be published in the District's Annual Report and/or the Water Resources Investlgations-NTIS series. An interpretive report comparing pre- versus post-dredging PCB levels will be published in Water, Air and Soil Pollution. In addition, a report comparing PCB concentrations in drinking water, raw water, and the river at Waterford will be published in an appropriate scientific journal. HONS 009423 A - 55 D. Hear Dradra Water Saaplint Plan MTgDEC. Bureau of Water lUaaarch It has been found Icoa fiva yaara of dradging monitoring work cowering five different projects In tha Hiadaon that: 1. Tha amount of aolida and PCS loat Co tha water coluan ta generally laaa than 2 percent of tha aaaa dradgad 2. Tha auapandad aolida and PCS incraaaaa in tha water coluan two ailoa or aora downstream of tha dradga have not baan significantly diffarant than background values upatraaa of tha dradga. 3. Tha raturn flow froa tha apoila lagoon rapraaanta tha largaac potential loaa of PCB and aolida froa tha dredging procaaa. Thia can easily be ainiaisad bp treataent and cloaalp aoniCored. 4. The vorat caaa condition ia likalp at a low flow. loucine aaapling upatraaa and downatraaa of dradgaa bp tha Corpe of CngiMara alao aeldoa ahowa anp aignificant diffarance. Thua the approach to ha uaed involvaa periodic, intenaivo aaapling atudiea downatraaa of the dradga with sensitive underwater tranaaiaaoaecer or flow-thru turbidiaatera. Turbidity raadinga and auapandad aolida analyaaa will be dona along with PCB. PCB water aaaplea will ba taken bp USCS depth integrating water aaaplaa auch aa tha OH 76-204 with reliance waahed glaaa aaple bottlea. Thera will be three of theae intenaiva aaapling atudiea during a dredging aaaaon: ona iaaadiately after dredging atarta up, ona during low flow and one during typical flow conditiona. Thirty PCB aaaplaa are planned. Helicopter aerial photography will ba conducted during one of thoaa runa to aid in defining the pluaa. Tha aaapling data will ba analysed by a ona diaenaional advectiva transport nodal considering both desorption and settling developed by Or. Mark Brown. HONS 009424 The fdiced* with existing tre Hudson River lee* In collecting fli H pal a v*re from 19TT t objective of eat effort vlll ccaf om1m4 for tm scheduled usyl scheduled trend work which to related project Robert Re collection coo Robert Mltchcl follow t seepllr* eehe ettochoent. Note: MONS 009425 BUDGET Travel and Inmfiti Contract* (to collect dally aedleant at 2 atatlona) Equipment replacement, repair and auppliaa Conputer charge* Sediment analyse* (daily at 2 station*) Lab analyses (170-200 PCB analyses per year) Oistrict common aervices Washington technical services ry'82* 74,600 1,250 1,750 1,000 750 2,750 10,000 12,100 6,400 ryai 76,900 2,750 3,850 2,200 1,6506,050 22,000 26,800 14.100 nr 84 84,400 7,000 4,000 2,400 1,800 6,500 24,200 29,400 15,400 nr* 85 92,800 3,700 4,400 2,600 2,000 7,000 26,600 32,200 16,900 rY'86** 38,300 5,000 4,000 13,700 6,000 TOTAL * r 4 70,600 \ * Charges for first half of fiscal year made to NT 77-046 1S6.100 171,100 187,800 66,600 * Tor completion of final sumary report and analysis of samples collected late Sumer and early fall of 1985 9 7 *6 0 0 SNOW 6. Hudon liver Fih Sanolios Sine* 1977 tbt RYSDEC has carried out an intensive program of fish flash monitoring for PCS in the Kudsoa giver. This has yielded an extenstive data baaa as wall aa a basis for sciancifie conclusions rsgarding eba impact of PCI on Cha Hudson Kiyar fishery as prssantsd in NYSDEC Technical Report 80-2 "Trends of Savsral Known Chemical Contaminants in Fish from Hav York State Haters." Attached is a summary of tha continuation of this program through tha duration of the project. HONS 009*27 T. Monitor Sediment Erosion and Burial ITBIC. Buroou of Motor Research Iron pipes have boon driven in as oroaion reference Barkers at various rivar locations. Survey and pipes were also driven in area 1 and in area 4 of the rennant deposits. These trill be surveyed every year by EEC for sediaant elevation changes. In_addition, three surveyed pipes installed by ITS (lectric and Cas around hot spot 37 north of lock 3 are monitored annually. It is anticipated that aiailar erosion pipes will be installed below lock 6 power plant, above lock 5 power plant, and above lock 2 power plant by the power developers involved. It is planned that the precise fathonetry and electronic ranging equipment will bn used by EEC just before dredging, just after dredging and two years after dredging Co determine any changes in river bottom elavecions. The equipment will reproduce horixontsl accuracy of 2 ft. and vertical accuracy of 0.2ft. A - 60 HONS 009428 4, > LOCATION Peekskill SPECIES StB Aa eel 1961-1905 HUPBOW HIYBR SAHPLIWO 8CHM NUMBERS PPUDJ COLLECTION DATE * 2 VKS SIZES AVE (RANGE) aa 30 Peak run Aa avail. 30 Aa avail. T.Z. Brdg ` AS StB * * .' VP Aa eel White catf1th G.V. Brdg StB 30 30 30 30 30 20 30 30 Peak run Early run Late run Pall -- ~ Early run Ldte run Aa avail. Aa avail. Aa avail. - As avail. Aa avail. Aa avail. - | As avail. As avail. ' Unspecified 3 i/> oosO *Ni YP StB Toacod T -- '-- t i """ 20 Dec.,Jan. As avail. REMARKS -at discretion of Region 3 personnel c 15*?j 1599 -collect not less than 3 vks later nor aore than 1 aonth -collect during shad run -tine of collection at dis cretion of collector u_ ' -collect not less than 3 vka later nor aore than 1 aonth -As available during saapllng of other species -As available through law enforceaent actions -- FISH FLESH CONTAMIRATIOIf PROlUCT TITLE PRIHCIPAL INVESTIGATOR n*m project nUTIATED puunm) ccmpletiom nWDIRG oEscRirnoB or PROJECT Monitoring PCB Contamination Levels In Hudson River Pish Flesh Dr. Ronald J. Sloan, Senior Scientist Bureau of Environmental Protection Departaent of Ehrlronaental Conservation 50 Volf Road - Room 526 Albany, Rev York 12233 Phone: (518) U57-6178 April 1977 I March 1986 . Unspecified amount by 1RS-DEC for collection of fish and administration of program. ' - $350,000 - Contract to Raltech Scientific Services 3301 Kinsman Boulevard - Madison, Wisconsin for laboratory analyses. The major objective of the project Is to monitor trends of PCB In fish flesh using the most Important commercial and sport fish species of the Hudson by analyzing the' concen trations of three Aroclor mixtures (1016, 1221, 125fc). This objective includes Identifying changes In PCB concen tration- as a result Of dredging operations. Seven sampling stations have been established since' 1977- From the George Washington Bridge to Poughkeepsie, four areas vere selected to sample anadromous species such as striped baas and American shad. Three stations from Catsklll to Stillwater were established to sample resident species such as largemouth bass, vhite perch and goldfish. Other location^ have been sampled as the need arose. The 1985 sampling will be the last major year of collection, the amphaeis will be on evaluating trends of PCB contamination. The current sampling protocol and a copy of the contract for PCB analyses are attached. MONS 009430 .lacca^uivc.rerrrate sampling Study 1. SUMMARY OF PROPOSED WORK FOR WHICH SUPPORT IS REQUESTED The major objective of this work is to develop and apply a sansitlva biological technique for monitoring tha lavals of PCBs in tha Uppar Hudson Rivar during "hot-*pot" dredging, whan highly contaminated sadiaants will bo ramovad from tha rivar. In ordar to accomplish this, mathods will ba davalopod to axposa uncontaminatad organisaia in tha watar column both abova'and balow tha dradga sita. During tha dradging, tost organisms will ba axposad and harvostad avary two waaks than weighed and thair tissues axtractad. Tha extracts will ba delivered to the Haw fork State Department of Environmental Conservation for analysis. Macroinvertebrates ara ideally suited for this work because they rapidly concentrate PCSa in thair tissues at lavals far greater than tha concentration in the ambient watar. Prior to tha cononancamanc of dredging, various candidate organisms will ba evaluated based on availability, sur vival in exposure cages, rata of uptaka and bioconcantration capabilities. During drudging, exposures will be made above tha dredging sita, at a fixed distance balow tha dredging aita and at a fixed station.(Routs 29 bridgs in Schuyiervills) to dstermina any inersased input to tha rivar below tha dradging sitae. ^ Tha- information ganaratad from this work not only will provids specific answers regarding-eny increases in tha PCB content of tha Hudson River but hopefully also will yisld a monitoring strategy that can ba used to assess tha severity and distribution of organic compounds In ether fresh wstsr systems. 2. INTRODUCTION During tha early part of tha 1900'a parts of the Upper Hudson River between Lock 7 (Ft. Edward) and Lock 5 (Northumberland) will ba dredged MONS 009431 >1 location Above Feeder Dan ' Stlllvater Albeny/Troy. ' 1961-a; Hudson urn* sampling senna SPECIES NUMBERS DE8IPED COLUCTIOr DATEt2 WK SIZES Pkad PKsd yp BB LeB Goldfish Pksd Pksd BB WP Avlfe/blb herring 75 75 30 30 30 30 75 75 30 30 40 9/20 9/20 6/23 6/21 6/16 6/22 9/20 -- 6/6 6/15 Peak run -- 213(193-261) 251(178-315) 325(203-384) 274(2_34-328) -- 292(193-338) 197(152-277) As avail. patsklll Pksd Pksd X0 WP t/i LnB 0 yp 0 Redbreast sunflsh sC + Avlfe/blb herring Ui Kingston/ Saugertles Poughkeepsie Avlfe/blb herring StB An eel 75 75 20 20 20 20 4o 40 30 30 9/20 9/20 -- _ 5/18 6/21 , Peak run . -- --. 206(163-264) 166(140-185) As.avail. Peak run As avail. Peak run --< As avail. As avail. Mewburg- Pksd 7; Pksd 9" .1 j3 i BBtARKS -ace It for Pk*d - 2+,3+,4* 1+ for Pksd -acea 2+,3+,4+ -Spaeles to be.subnltted dependent upon catch -age 1+ for Pkad -ages 2*,3+,4+ -at discretion of Region 4 personnel -Species to bs subeitted dependent upon catch -to be submitted dependant upon catch -at discretion of Region 3 personnel -age 1+ for Pksd contamination found in field-collected organisms will have baan accuaaalatad elosa to tha eo 11 action sita and over a ralativaly short period of tim. Piald collected macroinvertebratas already hava baan usad for monitoring tha lavals of PCSs in various waterways including tha Upper Mississippi River (Mauclt and Olson 1977), Raritan Bay (Stainken and Rollwagan 1979) and tha Uppar Hudson River (Simpson, unpublished data). Because fish are longar lived and more mobile, concentrations of contaminants found in their tissues may not reflect the contaminant burden at tha time and location where tha organisms ware collected. Analysis of macroinvertebrate tissues also offers advantages over water samples. Macroinvertebratas rapidly bioconcentrata certain organic contaminants (including PCBs) to levels many thousands of times greater than levels in tha surrounding water-- Because tha concentrations are higher, the organisms are more easily and accurately analysed than water samples. Tha results also indicate a direct biological impact by the substances in question. Results from static bioassays indicate that bioconcentration factors vary considerable between different species, but many.fall in the range of from 37,000 to 100,000 (bioconcentration factor concentration in tha organism/concentration in tha surrounding water) (Mayer, Mehrle and Sanders 1977; Itabeker and, JPuglisi 1974; Sanders and Chandler 1972; Stalling and Mayar 1972). Uptake rates also vary considerably: soma species reach equilibrium with the surrounding water altar only two days while ocher organisms (such as crayfish) do not reach equilibrium even after 28 days (Stalling and flayer 1972). Small organisms with thin cuticles prcbably have more rapid uptake rates than larger organisms HONS 009433 ATTACHMENT II COIAECTIOK PROCEDURE A. Following doc* *rt Co ba taken on ch fish collected: 1. Data collected. 2. Spools* Identification (plaasa ba explicit enough to enable assigning genus and speclas) 3. Total length and weight. A. Method of collection (gill net, hook and line, etc.) 3. Saaipla location (Waterway and nearest prominent Identifiable landmark). 6. Sax - fish may be cut enough to allow sexing but do not eviscerate. 7. Tag number (each specimen to ba Individually tagged with jaw tag). The original of all collection record and continuity of evidence farm shall accompany delivery of fish to the lab. A copy shall be directed to Ian Sloan. All necessary forms will be supplied bv the Bureau of Environ mental Protection. B. Each fish to ba wrapped In a plastic bag.. The Bureau of Environmental Protection will supply tha bags. C. Croups of fish, by spaclas, to be placed In one latge plastic bag par sampling location. The Bureau of Environmental Protection will supply tha larrer bats. ' D. Do not eviscerate. . E. All flah must be kept at temperature below 457 Immediately following data processing. Freer* as soon as possible'. F. Prior to any delivery of fish, coordinate delivery with and send coptas of tha collection racords and continuity of evidence forms to: Eon Sloan Bureau of Environmental Protection Room 326 SO WOlf Road Albany, NY 12233 " Telephone: (318)457-1769 ' Samples will then be directed to: Analytical facility and personnel noted on specific project descriptions. HONS 009434 The prim* candidate foe use is the nidge Chirononus riparius Meigen. This organism is easily cultured in large numbers in the laboratory (Bievar 1*05) and other species in the genus have been shown to rapidly bioconeentrate organic hydrocarbons (Derr and Zabik 1974). ' In fact, Derr and Zabik (1974) found that larvae of Chirononus tentans accumulate DDE at the same rate whether alive or dead. A laboratory colony of midges will be established and field tests conducted to determine the organism's suitability as a test species. Individuals will be harvested from the laboratory stock, placed in exposure cages and placed in the river for periods of 1, 2, 3, 4 and 7 days. Upon removal, the organisms will be examined to determine mortality rata, than placed on ice and returned to the laboratory, in the lab, the organisms will be weighed, freeze dried, reweighed and then extracted using the Sohxlet method. The extracts (ready for injection into a gas chromatograph) will be submitted to the New York state Depertment of Environmental Conservation for analysis. The analytical results.will be used to construct an uptake rate curve, plotting concentration against time. Additional exposures will be made to refine the uptake curve and to determine the length of time necessary for the organisms achieve a relatively stable body burden of PCBs. During the methods development phase of this project, results must be obtained from the analytical laboratory within two weeks from the time the extracts are submitted, so that ' follow-up exposures can be planned and performed. The final uptaka rate curve will be used to determine the length of exposure to be used during the actual monitoring. Additionally it will Indicate the levols accumulated by the test organisms prior to the initiation of dredging, thereby serving as baseline data. If problems ere encountered in using midges as the test organism (e.g. high mortality ir. exposure cages, inconsistsne uptake rates, etc.) the usefuXXness MQNS 009435  to rovo *odimnt* that are highly contandnatad with PCD* (polychlorinatod biphanyla). In .preparation for this work, spacial attempts have been made to select dredging methods that will minimize tha release of FCSs into the river during the actual dredging. Hopefully the removal of that* "hot spots" will load to subsequent reductions in tho Xovols of PCBs in tho sediments, wotor and biota of the Hudson River. In order to assess the short- and long-term effects of the dredging on the river, sampling programs havs bsen dsveloped for monitoring the levels of PCBs in the voter, sediments, fish and macroinvertsbratss before, during end after the. dredging activities. This proposal describee the sole of macroinvertsbratss in the overall monitoring strategy. 3. MOCGKXJHD Macroinvertsbratss are an important component of aquatic ecosystems, occupying tha intermediate position (in teems of both size and energy flow) between microorganisms (bacteria, algae end zooplankton) and vartabratss. Tha many kinds of frsshwatar macroinvartsbrstts include aquatic insects and other arthropods, snails, clams and various worms. Because they are relatively immohila (compared with fiah) and are sensitive to changes in water chemistry, they often are used in biological monitoring programs to assess the relative health of surface waters (Gaufin 1973; Goodnight .1973) . In disruptad (or polluted) habitats, the severity and qenaral type of stress involved usually can be determined by analysing the structure and composition of the indigenous macroinvertabrate community. Those organisms also have the potential for being an important com ponent of toxic substance monitoring programs. Most organisms ars relatively Immobile and have life cycles of ono year or less. Consequently, any MONS 009436 a _ ea the dredging end the final site will monitor the levels of Peas being released downstream. The length of exposure will ba determined during methods develop ment (see above) but is expected to be between 4 and 7 days. Exposed organisms will be placed on ice and returned to the laboratory, then weighed, freeze dried end reweighed. They will then ba extracted (as time permits) with hexana using the Sohxlat method and the extracts submitted to the New York State Department of Environmental Conservation for analysis. - While the dredge is in operation (approximately six months each year) exposures will be mads every two weeks. This will result in approximately M samples for analysis for each six month dredging period (14 samples/ month X 6 months). . d. rlnantlal support requested $77,077. This will provide l1] man-years of service by an Assistant Research Scientist (GS-14), 8 man-months of servica by a laboratory Technician (GS-9), travel expenses, supplies and overhead to ba paid to Health Research, Inc. (see proposed budget, pp. 11-13). a. work assignments _ 1. Principal Investigator - Dr. Karl w. Simpson a. Oversee, review and approve efforts and decisions of co-investigator s b. Edit and review reports 3.'Co-investigator - to be-appointed a. Evaluate suitability of midge larvae as test organism b. Design and oversae construction of exposure apparatus c. Supervise and participate in field and laboratory work (sample collection and extraction) d. Prepare reports describing results and their significance 3. Laboratory technician - to be appointed a. Assist in construction and maintenance of exposure apparatus HONS 009437 ' vlUi eiiiekar. Its* pBnwibl# cuticles. Due to the rapid uptaka racas and high bioconcantration factors of macroinvertabrates, it is possible to placa uncontaminated specimens in tha watar column for a few days in order to monitor lavels of contami nation at different times and locations. Clams hava bean usad for mon itoring organic hydrocarbon contamination in both freshwater and marine habitita (Arimoto and Tang 1980; Bedford, itoelofs and Zabik 196B; Butlar 1979). 4. SHORT TERM MONITORING. a. Obiactive TO develop and apply a Banaltive biological technique for monitoring levels of PCBa in tha Upper Hudson River during hot-spot dredging. b. Background Since soma nacroinvartabratas rapidly bioconcsntrata PCBs (see pp. 3-4) uneontamineted organisms will be placed in cages for several days and allowed to absorb PCS* from the water column. This work involves both development of methoda and thair implementation (actual eonitoring). c. Datallad work plan 1. Mathoda development - Prior to commencement of dredging tha precise nethoda to be employed will be developed. This will include preliminary testing of the tjt organism and the design and construction of cages to be used for the field exposures. Tha test organism should meat tha following criteria! 1) should be easily obtalnabls in largs quantities whenever a test is to be performed; 2) should have high survival rata in the test cages; 3) should hava rapid uptake rata; and 4) should have a high bioconcentration factor that is relatively consistent during different exposures. - HONS 009438 A - 70 XX. Long-term ***ct* A. Objective - % determine if removal of contaminated sediaianta reduces levels of PC's in tha biota of the Hudson Rivar (DEC program no. A-4). B. Background - One activity of tha New York State Biological Monitoring Project is the collection and analysis of caddisfly larvae (from tha Upper Hudson) and artificial substrata residues (from tha upper and lower rivers) for vea content. Data are available for each year beginning in 1976 (1976 for the eaddlsflies) and provide a good ,historical base for monitoring future trends. A continuation of this work would provide tha desired information. C. Work plan 1. Artificial substrates a. Install samplers at 16 station (Hudson Falls to Haverstraw Bay) in Hay or each year (see attached map) b. Harvest samplers an install fresh samplers at 5-week intervals in June. July, and August. c. Hake, final harvest and remove samplers in late September/ early October. 2. Caddisfly larvae a. Collect caddisfly larvae from 5 riffles in Upper Hudson River in Hay, June, July, August and September (concurrent with collection of artificial substrate sampling). b. Identify to species and submit for analysis. D. tkmfeer of samples generated 1. Artificial substrates 1 sample/station X 16 stations + 3 replicates X 4 harvests/ year " 76 samples/year (quality control) 2. Caddisfly larvae 2 aaspies/station X 5 stations X 5 collections/year - SO samples/year 3. Total samples < 76 multiplates * SO eaddlsflies - 126/ year E. Manpower required * 3-man field crew/ survey X S surveys X 5 days/survey 7S man-days/year HONS 009439 of other organisms will bo evaluated. Alternate tost organisms includo frashwoeor clams, nec-Spinning caddisfliea (Trichoptera:Hydropsychidaa) and fresh- watar shrimp (Amphipoda:Canmaridas). Thsss organisms havs boon rajactsd as tha prims tsst organism for tha following raasons: Clams - Ara ralacivaly largo and probably hava slow upeaka ratat , axposura would hava to be for savoral weeks. - May 'shut down" (stop filtaring water) in tha prssanca of irritants such as silt and FCBs ralaasad by dradgingj filtaring ratos may diffar at control and tost sita. Caddisfly larvae - Cannot ba maintainad aasily in tha laboratory; tast organisms ' would hava to ba field-collected from uncontaminated straws; dua to life history pattsms, sufficient biosass may not always ba available. - Require current spaed for survival; consequently survival in slow-moving areas (where dredging will ba dona) may ba vary low. Scuds - Do not reproduce as rapidly as midges in laboratory colonies. - Body weight is relatively low, requiring larga numbers in each test cage. 2. Implementation of methods (actual monitoring)- During dredging, vxicontaminated organisms will be obtained from tha laboratory stock and a portion of them retained and preserved for control purposes. They vill be extracted and analysed to assure that they are uncontaminated when placed in the field. Tha remaining orqanisms will be divided into six groups of approximately 200 mg each and each group placed in an axposure cage. Two cages will be placed at each of throe sitas: approximately 500 meters upstream of the dredge site, about S00 meters downstream of the dredge sita, and at tha Route 29 bridge in Schuylarvilla. The first two sites will reveal any difference in PC3 burden caused by HONS 009440 LITERATURE CITED Arimoto, R. And S.Y. Feng. 1980. Changes in ths levels of PCB's in (lytilus adulis associated with dredge spoil disposal. Oases Cone. 110, Mar. Sci. Inst.. Univ. Conn. 14 pp. Bedford, J.W., E.W. Roelofs and M.J. Zabik. 1968. The freshwater srassal as a biological seniter of posticida concentrations in a lotic anvironsMnt. Limnol. Oeaanogr. 13:118-126. . Biaver, K.D. 196S. A rearing technique for the colonization of chlroiuxaid midges. Ann. Entomol. Soc. Am. 58(2):135-136. Sutler, P.A. 1979. Use of oysters and related molluscs as biological monitors of synthetic organic pollutants, pp. 156-164 In Luepka, N.P., ed. Monitoring environmental materials and specimen banking. Martinus Nijhoff (The Hague). 591 pp. Derr, S.X. and M.J. Zabik. 1974. Bioactive compounds in the aquatic environ ment: studies on the mode of uptake of DOB by the aquatic midge Chironoeeis .tentans (DipteraiChironomidae). Arch. Environ. Contam. Toxicol. 2 (2):152- 164. " Caufin. A-A- 1973. Use of macroinvertebratee in the assessment of water quality, pp. 96-116 In Cairns. J., Jr. and X.L. Dickson, ads. Biological methods for the assessment of water quality. Am.Soc. Test. Mat., Spec. Pi*l. No. 528. Goodnight, C.J. 1973. The use of macroinvertebrates as Indicators of stream pollution. Trans. Am. Hicrosc. Soc. 92:1-13. Mauck, W.L. and L.E. Olson. 1977. Polychlorinated biphenyls in adult mayflies (Hexaqenia bilineata) from the Upper Mississippi River. Bull. Environ. Contam. Toxicol. 7(4):387-390. Mayer, F.L., P.M. Mehrle and H.O. Sanders. 1977. Residue dynamics and biologi cal effects of polychlorinated biphenyls in aquatic organisms. Arch. Environ. Contam. Toxicol.:501-511. :tebeker', A.V. and F.A. Puglisir' 1974. Effect of polychlorinated biphenyl's (PCB's) on survival and reproduction of Daphnla, Gammarus, and Tanvtarsue. Trans. Am. Fish. Soc. 103(4):722-728. Sanders, H.O. and J.H. Chandler. 1972. Biological magnification of a polychlor inated biphenyl (Aroclor 1254) from water by aquetic invertebrates. Bull. Environ. Contam. Toxicol. (5):257-263. Stalnken, D. and J. Rollwagen. 1979. PCS residues in bivalves and sediments of Raritan Bay. Bull. Environ. Contam. Toxicol. 23(4-5)=690-697. SSallinq, D.L. and F.L. Mayor, Jr. 1972. Toxicities of PCB's to fish and environmental residues. Environ. Health Persp. April 1972:159-164. M0NS 009441 b. Assist with fiold work c. Assist, with laboratory work (weighing and extraction of saa^les) S. ADDITIONAL WORK (long-tare oonitoring) As part of the ongoing biological atreaai surveillance(cograa the long term effects of PCS dredging activities on the biota of the Upper Hudson River will be studied. Since 1977, net-spinning caddisfly larvae (Trichoptera: Rydropsychidae) - have been collected during the suseeer months from 5 sites In the Upper Hudson River (Hudson Falls, Ft. Edward, Thompson Island, Still water and Waterford) and their tissues analysed for PCS content (Figure 1). This program was initiated to help sonitor the temporal and spatial changes of PCS contamination in the upper river. These activities will be continued unaodified. The long-term impact of dredging can be evaluated by comparing post-dredging concentrations in these organisms (1982-1985) with pre-dredging values (1977-1981). During each year from 1982-1985, net-spinning eaddisflies will be collected in June, July, August and September at the five sites shown on rigure 1 and their tissues analysed for PCS content. Results from stations 1 and 2 will show levels of pens in areas unaffected by the dredging and the results compered with historical data (1977-1981) to determine the consistency of background contamination. The remaining stations are either in (station 3) or downstream from (stations 4..and 5) the areas to be dredged. If dredging does reduce the burden of PCBs to the biota of the river, concentrations at the last 3 sitas should decline after the dredging is completed. Ik> funds are requested for this portion of the monitoring program. The work will be performed as part of the routine activities of the Biological Strean Monitoring Project. HONS 009942 particle* In wacer, !.* a ouch lower surface area per unit al> aobillty with the associated greater likelihood of bacterial ce clos*f'.',proxtnicy to high organic itfotltt derived fro* underly effects of bloturbatlon. These lialtatlons have led to nlcrocosa designs utllieie allow release race estlBsces fton a eore realistically scrag Interface. Sediaents used in these experlaents have been eJ (Halter and Johnson 19771 or eontaalnated natural sedlaeata and Sowers 1981). Results froa chess studies (Table l) la concentrations within a given aethad correlates with rele* the aethod Itself partially dictates results Independent densities. Partition coefficients froa the 'shake in th generally rang* froa 10^ to 10-, while nlcrocosa estlaat at toMo5. The flow through nlcrocosa experlnenta are perticthay, aore chan any ocher laboratory approach, slanlat sediaents. Two flow rata dependent aechanlsna have b nose of the PCS* released froa river sediaents. At ` slowly through desorption, while sc high flow rates particles inco the water coluan account* for aost P (Malcole Plrnle Inc. 19807. Field data froa the > this hypothesis (Heeling ct al. 1978). River wets highest during periods of low and high flow with occurring at iiiteraedist* races. *0s 009443 Figure I. Collection sites for long-term bionoiiitoring of PC3s. HONS 009444 Three ehnngcs are envisioned for the present system. First to preserve the physics) condition of the sediment samples ss they occur in the river, temples will he collected ulth e box type eorer. The teet cheaber will then be built to accomodate this sample size. Secondly, the currently utilized pump ulll be replaced by one capable of accurate and precise flow race control. Finally, the complete system ulll be maintained under controlled lighting and temperature during the coursa of the studies. Testing the first three hypotheses ulll utilize the same experimental design. Replicate flou through trials ulll be performed at approximately six flou velocities to define the functional relationship between PCS release and flow raee. Conducted at 16--18*C and under constant low-flouresceat light the experiments ulll run for tuenty four hours. PCBs analyzed from the uater column util be partitioned into soluble and particulate fractions. Thus at lov flow rates, ehan desorption could be the dominant release mechanism, the soluble PCX fraction should constitute the majority of PCBs in the uater column. When sediment particles are swept off the sediment interface at high flow rates, the particulate bound fraction should dominate. ` Aaseselng the effects of sediment quality will also follou the sane experimental conditions ulth release rates versus flou rates defined for four different sediment types. Three sediment types will be collected from 'hot spots* (>30ug g"1) near the discharge dources (Reach 8; Tofflcmlre 1979) and one sediment type from a downstream location near the Troy Dam. The 'hot spot* samples will be of the silt, muck and sand with wood chips types because of their known capacity .to contain high PCB concentrations In Che river (Tefflenlre 1979). Either a silty or muck type sample will be used from the downstream sampling station. In conjunction with the release experiments, Che four MONS 009445 ' J. Study of TO Balaaaa from Hudson Hrr Sedlaents .\r.xrnoir-:n Polyehlorinactd biphenyls hnvt contaminated the Hudson River ecosystem for th post twenty five years. This was principally due to discharges froa electric cspscltor factories located at Fort Edward and Hudson Falls. Today a forty allq lncerval of the river froa the Troy Dam near Albany to Fort Edward Is one of the aost PCB burdened freshwater systeas in Worth Anarlca. When entering aquatic systeas, FCBs (due to their low solubility In water and their high octanoliwater partition coefficients) usually becoae strongly sorbed onto suspended particles, especially those high In organic content (national Research Council 1979). Thus bottom sediments such as the "hoc spocs* In the Hudson River Initially fora an lnportant immobilizing sink for FCBs. Once In the sediments FCBs are desorbed at low races, resuspended and distributed by physical disturbance of the sedlaents, or redistributed by bloturbatlon (Halter and Johnson 1977). With a known FC8 affinity for the organic fraction in suspended solids (Hading et al. 1978; Dexter and Favlou 1978), Halter and Johnson (1977) suggested a variety of sediaant types having different proportions of organic aacctr be assessed for differential release rates. Benthic aacrolnvertebrates, which rapidly accumulate FCBs (Hansen et al. 1976), also nay translocate FCBs through their foraging and burrowing patterns. However, bloturbatlon effects on release rates are presently unknown. Although aost research has focuse<F upon sorption of FCBs onto particles, several studies have estlaaced release rates from lake or river sedlaents. Several employ the 'shake In the tube* method where PCB laden sediments are alxed with measured amounts of wacer in a cancrlfuge tube. After s period of vigorous shaking, Che sediments are spun down, and chc water analyzed. However, the sedlaent wacer interface has many features quite different from suspended HONS 00944b PU.`l Of wnnic 1. Determination of sampling stations. 2. SampIs collection with box typo eorar. 3. Sediment analysis, classification and ?CB determinations. 4. `Pilot- trials with tha redesigned system. 5. Experiments defining release rate curves. 6. Comparison of sediments. 7. Testing of temperature effects. 8. Incorporating Che findings Into a transport model. 9. Calibration and verification of transport models. MGNS 009447 rnurcrms Based on Cha above observation* our research objectives are to teat the following hypotheses using our own Microcosm design. 1. Whan flow ratas inersase from isro, PCB concentrations are initially Inversely correlated to flow rate and at soma relatively lnteraediats flow velocity this correlation becomes positive. 2. At low flow rates dasorptlon Is the principal release nechanlsm. 3. During high flow rats conditions sediment erosion, with most FCBs partlculately bound, produce high PCB concentrations In the water column. 4. The functional relationship between PCB desorption rates and flow velocity will differ between sedlaenc types. 5. Temperstura willsignificantly alter release rates at low flow velocities. 6. Our empirical release rate estlaatas when used In a aodellng framework ' will favorably compare with the USGS data. METHODS . Our basic experimental aaehod will be a flow through type laboratory alcrocosa, presently being applied to lake and river sedlnents (Fig. 1, Rice and lowers 1981). In this- chamber water Is pumped over a 1 to 2 cm layer of natural PCB ladanad sedlaenc. The magnitude and race of PCB release is then estimated by changes in PCB concentrations in the water leaving Che chamber. The water is first filtered through a glass fiber filter for estimating partlculately sorbed PCBs and then passed through polyurethane foam plugs to capture soluble PCBs (Velth at al. 1977). Precautions regarding PCBs entering the chamber, water turbulence over Che sediments and PCB adsorpeion onto the chamber vails are observed. MONS 009448 PCI Samr1'"fl| Analvaio and Data Flow Summary introduction The aampling for PCS ia outlined in thrao flow charta; (1) pre-dredging, (2) during dredging and (3) poat-dradging. There outlinaa to give an overview of the environmental monitoring program, data analyaia and contingency plan implementation. HONS 009449 sediment types will be analysed with regard co grain size and organic carbon content. Also PCI depth profiles of tha four samples will be performed Including relative isomeric changes with depth. Testing for temperature effects upon sedlnent release rates, ue will utilise a silty sadlaant froei a near source sampling station at a low flow rate. All of the trials will be run In triplicate. Each experlaent will follow a three teaperature pattern. The first twenty four hour period will run at 1820*C to be followed by another twenty four hour period at 10*-12*C. Then a final period will run at the Initial tenperature. _ Throughout the data sat PCBs will be aeasured in two forms. All of the data will first be reported as the Aroclor derivatives 1232, 1242 (1016) and 12S4. These derivatives will be determined from at least three CC peaks for each Aroclor using packed column gas chromatographic results. Approximately ten per cane of the water samples and all of the sediments will be analysed on a capillary column CC. Data output from this methodology will permit the assessment of PCS "weathering' where PCS Isomer proportions are known. Statistical testing will follow general parametric technique*. The shape of the PCI release raee curves will be defined by polynomial regression equations. Data sets requiring comparative testing will employ common analysis of variance protocols. The output from the experiments will be used to describe the release and transport of PCS* from the sediment of the river. The pxtsclng Lawler, Metusky anil Welly (I..M.S.) mode] (l')'/K) for lliln river ilenrrlbe irnnnporr solely on the basis of sediment transport. The model framework we plan to apply will be the Hydroscience (1973) adaptation of the L.M.S. model with the modification of adding a component for the dissolved release of PCBs directly from the sediment. HONS 009450 . m-piipcmc ptyi, -im mmiTotiwc mocmm on i e<6 * I TABLE 1. Gosperlion of FCB desorption froo sod toon Cs. Method Sedlaent PCI Concentration ( Static, continuous shaking In centrifuge tube, 2 hr duration 1000.0 (1254) Static, continuous shaking In teat tube, 24 hr duration * 231.0 (1254) 177.0 11242) 7.0 (1254) Method Hlcrocosa, flow throughi 6 days 116000.0 (1016) Static In 2.BL jars. lxing. 1-24 hrs., settling. 5-180 hrs. * 10000.0 to 300000.0 Hlcrocosa Static, 8 days 100000.0 (1254) Flow-through, 16 hr 100000.0 (1254) Hlcrocosa Scatlc, 7 days 495.4 (1242) 144.4 (1254) Mow through 0.7 hr 495.4 (1242) 144.4 (1254) Uater FCB Concentration ( g/L) 1.0 0.15 0.14 0.02 0.45 Scdiaant; Water Partition Coefficient Author l.OxlO3 ' 1.6xl03 1.3xl03 3.5x10* - 2.6x10' ! Wildish ' at al. 1980 folk at al. 1975 Velth 1976 2.0 to 6.0 1.7 . 0.11 ll.SxlO-3 12.2xlO~3 4.0al0-S 2.0x10-* 2.0x10-3 1.0x10-3 103-105 5.9x10* i 9.1x10s 4.2x10* 1.2x10* 1.2x10* 7.2x10* 2.5x10* 1.4x10* Tofflealre 1976 Halter 4 Johnson (1977) Bice 6 lowers 1981 HONS 0 0 9 4 5 2 POST-DtEDOIHC gMVIROWKtHTAl, HOHITOMHC WOCItAM i xs (A O o * Oj HONS 0 0 9 * 5 4 m-MttDCIHC EWyimt'ETTAL HOHITOKUtC FIOCUM rxr\ Quality Aaaurtnce/Quality Control A quality aeaurance/quallty control documnt ia being prepared in accordance with tha EFA doemont "InCerio Guidalina* and Specificationa for Preparing Quality Aaauranea Frojact Plana " (QAMS-005/80). To inaura a complete and accaptabla dociaaane ia prepared, private contract laba, IfYSDtC laba and ETSDOB laba doing work or planning to do work on tha project have boon contacted for Chair input. Tha project ataff ia currently waiting for repliea fron the appropriate laboracoriaa. An intagratad, conplete quality aaauranca/quality control documnt will be forwarded to EFA for approval. HONS 009455 wigc-Mppiiic DryiKowmiTAL aamnniB g>* comumacT yum mitoqik SSXULZSH FftOJECT C0WT10L FAUMtmS AMD SAHFLIMG WOGIAK PdlM TtMBMl SitaifiMDCll Wbtar Short IH2- Air/ Hotorolorr Itiifintj I MC hojMC Ub__________ tyoarlrl Stadia* I |Crof/Tof| * I Coraoll Lob | InwlM Inal Analyses lw>ct| |fUnf fMamtamtAraij loltoch*U56& UC-flaiMlM Data K-- tnti _ I Xmmkm Soctloal MiSk film ha. Caipllafi with Established Criteria EaUblUhad Criteria If1 --fit Contiafttcy I f*^l P^l Production Pau Location, Quantitl-- laiwal. Etc. ICoMtnetta Ceitmti ^^natlai Crops | upplf Fotablaj Hitar Soritea ttetor [ Sotlfy Ooorr/Xolt.Brodglat| CentalMast Slto ------------1------------ Add Adoorbooe Award bflaanone oluo naahWavda HONS 009456 with ehw um rulea of law aa applied to aetiona in tha aupreme court againat individual! or corporation, provided tha claimant compliaa with tha lialtationa of thia article." There ia an annual appropriation to cover the actual awards to claimanea and tha projected awarda of pending claiaa. In the atata budget for the fiacal Tear 1980-81 (Chapter SO of the Uwa of 1980) there ia an annual apropriation of 59 million for auch claima. In the current atata budget for fiacal year 1981-82 (Chapter SO of the lawa of 1981) there ia an annual appropriation of 912.5 million for auch claima. In addition the procedure in New York State ie that aupplemental and deficiency budget! are paaaad to cover any additional expenaea that ariae during the fiacal year. In addition it ia noted that the annual budget of Dew York State ia currently over $16 billion and ia baaed-on the taxing power of the State. Coeeequently, even if the atata were not exempt from the cloaure, poat-cloaure and liability requirement! of the KCBA regulationa it could eaaily meet the liability requirement! for audden and non-audden occurrencea of $4 million per occurrence, and an annual aggregate of at leaat $8 million, that are act forth in Part! 264.147 and 26S.147 of the RCRA regulationa. - There are no procedure! for grievance or arbitration of claima in con nection with the public health aapecta of the PCS reclamation project. Aa atated prevloualy. The Court of Claiaa Act not only waivea immunity by the State, but alao provide! the procedure! by tdiich claiaa can be proceaaed. There ia no direct or indirect authority in that atatute providing for informal reaolution of claiaa againat the atate. Specific atatutea, auch aa Article 11 of the Navigation Law (concerning oil apill prevention, control, and coapen- aation), would have to be enacced inatituting an arbitration procedure for claiaa auch aa found in Part 3 of Article 12. Such cnactmenc of arbitration procedure! for poaeible future claiaa ia not adviaable given the exiating HONS 00945 7 F08T-Pn)CMC PnriMMHDITAL HOWITOtDK. FKOOULM \ oz* in oO *0U*3l hesardous waste facility for purposes of compliance with th closure, post-closure and liability financial requirements if tha atata assumes legal raaponaiblity (which ia tha caaa hara ainca New York Stata ia tha ownar and oparator). Aa noted above, New York State has adequate financial resources in tha annual appropriation for judgements from tha court of claims, and in annual tax revenuaa of $16 billion, sufficient to assure financial raaponaiblity. Liability insurance for eny claias arising in connection with tha public health aspects of tha project is consequently not necessary for any potential claias resulting froa sudden releasee. In addition state law prohibits "personal injurty liability insurance" for non-sudden releases of pollutants or contaainanta (Insurance lav 146.13). One exception to this is insurance "ourchescd to satisfy the financial responsibility requirements of any Federal law" but RSCA does not contain any financial responsibltty requireaente for this project. RCRA on the other hand, has financial responsibility require ments, but RCRA does not apply to this facility. The forth modification requested under 'Long-term Storage" is provision for specific funding mechanisms by KYSDEC to assure implementation of long-term contingency plan, operation, maintenance and monitoring. A serious obstacle to this ia S 41 of the State Finance Law which prohibits any State official from binding the State in excess of appropriations. In th absence of an appropriation to cover the entire post-closure period, which is unlikely, no binding assurance of the availability of such funds can be given. However, as discussed above, the resources of the state ere more than adequate to eeaure that such funding is available. Consequently, there should be no requirement, such as found under Section 264.145 concerning financial assurances for post-closure monitoring and maintenance, that tha state be subjected to establishment of either a post-closure trust fund, a surety bond guaranteeing MGNS 0094S9 91. Liability ad Financial Anurtncti Xn assessing the necessity acid function of tho financial aaauranca recomeendations in tha OCXS, tha following ahould be conaidarad: (1) Haw York State has waived lea Immunity from liability, ia a selfinaurar for purpoaaa of auch claims and thara are existing atata procedures to ajodieata auch claims in tha Court of Claims. (2) Thara ia no authority for an arbitration procedure for auch elatms for injury to public health and lagialation would be nacaaaary to require auch arbitration pro'eeduree. O) Tha fCl Reclamation Project ia being reviewed by CPA under tha Tonic Substance Control Act (TSCA) which contains no financial responsi** b11icy requirements for the owners and operators of chemical waste landfills. However, the financial raaponaiblity requirements of the Resource Conservation Recovery Act (RCRA) provide guidance on the nature of financial easurancea that could be pert of the PCS project. However under RCRA regulation#, federal and atate government# are axempeed from the financial raaponaiblity requiremanca for cloture, post-closure and liability. (4) Nevertheless, tha state e#n meet the financial requirements of RCRA because of its general resources, and more specifically because of its taxing power and appropriations for claims. Last century New York State waived immunity from site with reference to such casues of eetions (torts) by its eitisnes for injuries due to governawntel activities. The current law for filing and processing claims against the state ia the Court of Claims Act and its~attndanc rules. That set, in Section S, states that "the State hereby waives its immunity from liability and action and hereby assumes liability and consants to have the same determined in accordance HONS 009460 VII. LEACHATI AMU CAS COLUCTIOH SYSTEMS A. Leachate Collection System 1. Goners1 During approximately two year* after cloture of a containment call, an initial dewatering of excess water will take place at an average rate of SO gallons per ainute (gpa). At the eetiaated rate of leakage through the cell cap of 1.25 inehee of water per year, the total long-term leachate flow froa both calls of the "rescoped" project will average one gpa. 2. Leachate Collection Systsa Design The leachate collection tystea is shown on Place No. 13 of tha Site Design Report, September 1980. Essentially, it consists of the following components: * Sloped bottoa of containment area * Cravel fillad collection trenches, wrapped with filter fabric * Perforated drainage piping in the collection trenches * Collection and saapling wells on the containment area perimeter, connected to the drainage piping ' Piping system connecting the drainage system to a discharge point at the Hudson * Plow metering and aonitoring system The leachate collecting systea will be valved. Discharge to Hudson will taka place if leachate quantities and concentration observed are in compliance with the conditions of the site discharge permit. If the leachate contingency plan described in Section IV will be implemented. The use of filter fabric with the relatively sandy dredged material as sampled in the Thompson Island Pool and as anticipated in the lower river pools is a sound technique. Filter fabric will function as tall as HONS 009461 court of claiao procedure* to procea* eliiu againat tha ataca, and would probably ba raaiatad on general principle* by the legialatur*. In addition, auch a propoaal would require legislative anactaiant which ia unlikely thia lata in the aaaaion. Sine* th* PCS Reclamation Project la seeking approval under the requirements for TSCA, there ia no requirement that the projet meet tha technical financial reaponaiblity requirement* aet forth under the SCIA atatuc* and tha regulation*. Assuming, however, that the eloaure and poae-closur* requirement* for thia project could be aubatantially eh* aam* aa thoao for a haaardoua waate diapoaal facility under the RCXA regulation* (for example, the 30 year poat-cloaur* obligation of 40 CFR 265.145 ia aimilar to th* obligation of development of longterm maintenance and monitoring prognae for a minima* of thirty year* for thia project) then the RCRA regulation* on financial reaponai- bility, Subpart R of Part* 264 and 263, provide guidance on the financial requirement* that ahould or can be impoaed on Hew York State for th* PCI Reclamation Project. In auch a caa* both federal and state government are exempted from the financial requiremtn* of RCRA (40 CFR 264.140(c); 40 CTR 265.140(c) ) and conaequently no additional financial aaauanca* ahould ba required from New York State for thia project. The reaaoning behind auch an exemption la apecifically atated in th* aupplmentary information aection to the promulgated regulation* in the federal Regiater of Hay 19, 1980. In that comaentary, on page 33198, it atatea "the agency agree* that State and Federally owned faeilitia* will alway* have adequate reaourcea to conduct cloaur* and poat-cloaur* care activitiea properly. Therefore, an examption for the** faeilitia* haa been incorporated in a new "Applicability aection." Carrying thia principal further, 40 CTR 264.150 and 265.149 allow a atate to aubatitute for an owner and operator of a A- - 94 HONS 009462 In.general, MthMc guci |tur4tad in a landfill Cand Co riaa. If thla occurs, cho additional praasura could causa cha clay cap co breach. Also, pockacs of gases may ba formad in araas of highar organics, becorna crappad and moved lacarally through tha fill. To prevent any breach of Cha cap and any controlled raleaaa of gas, a gas collection system will be installed under tha containment area cover as shown on Plaea 3. 2. Uas Collection System Tha gas collection system will consist of the following components: * A network of gravel-filled collection eranchaa placed under cha clay cap cantered along the final ridge line of the clover. * Perforated piping placed in the collection trenches. * Crsvel-filled wells connected to the collection piping and axtending 20 feet into the fill. * Perforated piping placed in the walla. * Valved gas vents extending above the cover at each of the walla. ' * Piping system connections from the vents to possible treatment apparatus. The gas collection system will be valved. Sampling points will be provided at each of the vents and gas pressure and generation will be monitored regularly. As gas is generated, samples will be taken and tested. If the gee does not contain appreciable amounts of PCI, the valves will be left open. If testing indicates that treatment is required, piping will be installed from specific vents to the treatment apparatus. The gss wilt then be pumped through a carbon adsorbent and tested at Che point of discharge. The gas will then either be recycled through treatment or, if found to be acceptable, released. HONS 009463 payment into < poit-cloauro truoe fund, a lurocy bond guaranteeing performance of poat-eloaura ear*, a poat-cloaura letter of eradit or a combination of any of the above financial aachaniama. Conaequenely, tha atatua of Haw York State aa a aalf inaurar, for purpoaee of claina, and tha annual tax revanuaa of tha atato ahould provide aorc than adequate aaauranca of financial reaponaiblity to carry out poat-cloaura requirementa and to honor all valid claina. HONS 009464 VIII. OTHRR SITE OSES In tha ancapaulation sic* acraaning procaaa, poeantial aieaa vara judgad aolaly upon chair auicability for cha diapoaal of PCB-eoneaaiinaead dradga apoil froai Cha Uppar Hudaon Rivar. Tha nacariala originally propoaad to ba placad into tha aita by tha NYSDEC includad 40 "hot apoca" araaa, raanant dapoait araaa 3 and 3 and poaaibly NTSDOT diapoaal araaa Buoy 212 and Spacial Araa 13 and Buoy 204 annax. Sita panic application hava raquaaced approval for tha diapoaal of ehaaa nacariala only. At cha praaanc tioa, only nacariala dacaninad to ba a part of cha ra-acopad Hudaon Bivar PCB Raclanacion Project will ba placad in tha aita. Tha ranaining nacariala apacifiad in tha panic applicaciona nay ba ancapaulatad at tha aita at a latar data if funding ia aacurad. IC ia not Cha inCant of tha RYSCCC to diapoaa of othar chan PCB-contaninatad dradga aad inane natarial froa cha Uppar Hudaon Rivar in chia aita. Lagialatiou providing for thia aola uaa haa baan approvad by tha Haw York Stata Aaaanbly with tha acrong aupport of tha Naw York Staca Dapartnant of Enviroimantal Conaarvacion. MONS 009465 graded aggregate (liter. When aaae and dependability of construction are considered, fabric filtara have a better overall performance. Performance of the leachate collection system la dependent on the neture of dredged material In contact with the drain, particularly on the proportion of fine grained material contained. Provision haa been made in the design of- the collection system so es to prevent or minimise clogging, but if the dredged material contains a large proportion of fine grained material clogging may eventually occur in some portions of the leachate collection system. However, a key point Is that the leachate collection system offers a much easier pathway out of the containment area than percolation through the clay bottom. If thera ars sufficient fines to clog the collection system, they will also affectively seal the interface batveen the dredged material and the clay bottom, thus preventing any leachate escape at all. In that contingency it would be necessary to remove leachate through vertical wells located on the site. g. Caa Collection and Control ' 1. Ceneral In ordinary sanitary landfills recaiving municipal solid wastes, geses are generated as the result of the decomposition of organic materials. Iha dradged material contains an average of only five percent organics, but in seam areas may contain as much as 30 percent organics. Therefore, although the amount of gae generation expected is much less than that--at an ordinary solid waata landfill, the processes of waste volatilisation, biological degradation and chemical reaction may generate gaaaa. The actual production of gas will depend not only upon the amount of organic matter, but the temperature, moisture content and pH of the fill. A -"98 HONS 009466 humon wwt rca koamatun mojcct HOT SPOT SS N-MVOI CONTMMNT ---- HMflWM------- 3. Air Monitoring Aa pare of cho containaent sic* aonitoring, a continuoua air aonitoring progrua will ba iaplaaanced aa praacribad in tha aita air quality parait. Tbit will provida quality data oa any gaaaa ralaaaad from tha aita. A. Contraction Sequence In ordar to ainiaiaa PCS volatilization from tha containaont araaa during tha drudging procaaa, a aix-inch- taaporary covar ot aichar elaan dradgad aatarial or an organic aixturo will ba placed aa aoon aa poaaible over tha fill araa. Tha gaa collection ayataa will chan be inacalled before placeaent of tha clay eap and final eover. Aftar bringing tha fill to final grade, tha collection trenchaa will ba dug and tha gravel collection piping placed. Where opacified, boringe will ba aade to allow for the gaa collection wall. Tha aurface venta will ba aat in place aftar tha clay cap and final cover are placed and worked to final line and grade. S. Caa Collection Svatea Coata Tha coat of the gaa collection ayatew including collector trenchee, collector wella, gaa venta and contingenciea ia epproxiaately $1,300 acre. For the two propoeed concainaent cello, tha eaaterly with approxiuately 23 aeraa and tha weaterly with 1A eerea thia aamunta to epproxiaately $SA,000. The coat of treataent apparatua ia not included. Need for treataenc will depend upon the reaulta of tha initial taating. A - inn HONS 009468 Appendix A Seatline Environmental Sampling Hudson River PCS Reclamation Project ParaaMter Air Location*/Bescripcion 1/Hefner fern or Site 10' 1 Anelysio PCS Responsible Party Boyce Thompson for 1981-1982 yr contract Total p oi FREQ Sammies weekly w/ duplicates 100 A/Remnant depot its VRemnant deposits 6/Beanenc deposits 7/Lock C Dam 6/Ramnant deposits Hew Methods Plants PCS A,B,C,D Plant Plots K, ft. Miller Plant Plot natural Planta 4x4 " Lock t " Dredged sitea " Keenant dapoaita Same aa___ above Micro Sits 10 Heterology Air teap. wind dir. wind tpead dir. fluctu ation daw point, pre cipitation DEC and Boyce Thompson periodic in warm weather m Aa necessary 2/yr 16 16 16 12 16 SO 300 SO 100 20 IS 25 eontinuoue Sept., Oct., Bov., 1981 Restart 1982 Surface Veter River (see asp and monitoring plan) Hater Supplies PCS susp. solids uses PCS, susp. uses * solids, metals River flow dependent N ISO 26 'Location corresponds to attached nap HONS 009469 `To:................ From: ........... Sab|et....... HONS 009471 f _ V W ra* MMWr V m. rtTr^-- M M ..... "' *"'"1 """" ___ vmim (M couintN tmcu MALCOLM PIRN1E. INC Intsr-Offlce Correspondence T .... From; . Sutojaet Richard _ Thomas _ ........ -O.................. Brian Hood ...oM#:.................... Hudson Rivar Sadir^nt EP Toxicity Analyses bA?.3/!.1. Tabulated below are the results of the organics analyses on hot spots 27 and 28. Units are milligrams per liter. Parameter Bndrin Lindane Methoxychlor Toxaphene 2, 4-D 2, 4, 5-TP Hot Spot 27 <0.001 <0.01 <;.o <0.05 <1.0 <0.1 Hot Spot 28 <0.001 <0. 01 <1.0 <0.05 <1.0 <0.1 EPA Max. Limit 0.02 0.4 10.0 0.5 10.0 1.0 " MONS 009473 C-33CC) Appendix A Con'c Baseline Environaencal Saaplint Hudson River PCS Reclamation Project Parameter Ground Hater Location+/Bascription Analysis Buoy 212. SA 13 6 wells PCS Site 10, 6 walla PCB Rasponsibis Party csgs OSGS FREQ 1/mo l/ao Total t of Saawloa 60 to Bed inane Hot Spots PCB Total Solids **Syrscust Rastarch Corp. ss needed 130 Pith Sat map and monitorinf plan PCB, Lipids DEC 1-2/yr 600 Maeroinvar* Sat map and monitoring PCB, Lipids NTSDOH.DEC A/yr ttbrstas plan 126 ^Location corraaponda to attached aap ** Re EPA funds involved HONS 009474 MALCOLM PIRNIE, INC Previous transmittals giving results oC EP toxicity tests are a) MPI ammo of 3/20/81 (C-33A), b) MPI memo of 3/31/81 (C-33B), c) MPI memo of 4/23/81 (C-33C), d) MPI memo of 6/11/81 (C-33D). Very truly yours, MALCOLM P IE, INC. T. Thomas Project Manager RFTthkh cci Mr. Maher MOMS 009475 (4S7-IZ5+) jerr StriMirr "Km. S'l9 1 v.i Tee................... R. Thomas B. Hood MALCOLM PIRNIE. INC ^fj457-/aff Intar^Cffiea Conespondanca Jcb* zcc-zz-n&o 15; JEFF SZHtiiTT ?M5 4S7-US4Oats: ...3/3.VU.. Swb|acc Hudson Rivar Sediment Cora Analysis Job 266-22-1100 Two corn samples wara received 3/26, the samples ware labeled "hot spot 27* and "hot spot 28*. Par your instructions, the samples were analyzed for E. P. Toxicity and total metals. Results are tabulated below.' E. P. . extract units below are milligrams per liter, total metals are micrograms par grasi, dry weight. ` CORE 27 . E.P.EXTRACT Km 0.04 Ba <0.1 Cd <0.01 cr <0.05 Pb <0.1 Ag <0.01 Sa <0.005 Hg <0.0005 . TOTAL 3.4 . 20.5 0.32 11.9 20.9 0.45 :o.io CORE 28 E.P.EXTRACT ' TOTAL <0.005 <0.1 . <0.01 <0.05 <0.1 <0.01 <0.005 <0.0005 3.5 24.0 0.56 17.6 26.5 0.80 <0.10 I ) nous 009476 Hudson River Reclamation Project Stage 1 Cultural Resource Survey for Site 10 Abstract A cultural resource survey was conducted at the proposed PC8 con tainment site (site 10) in the town of Fort Edward, Washington County New York for the purpose of Identifying historic and/or prehistoric resources that could be Impacted by the proposed action. This Stage 1 survey included a literature review, sensitivity model for predicting areas likely to contain previously undiscovered resources, and systamatie field investigation. As a result of this study, thirteen (13) cultural resources were identified In the proposed project area. A Stage 2 cultural resource survey Is recommended for the purpose of evaluating the potential eligibility of selected resources for listing on the National Register of Historic Places. These.resources Include two (2) prehistoric sites and an old bam complex. It Is recomncnded that Impact be avoided to the west bank of the Dead Creek, an archeologlcally sensitive zone. Also, mitigating measures will be developed to minimize potential Impact to the Old Champlain Canal, a property listed on the National Register. B- 1 MONS 009477 APPENDIX B Stag* 1 Cultural Resource Survey for Site 10. Hudson River Reel anatlon Project, Abstract New York State Department of Environmental Conservation, 1981. Stage 1 Cultural Resources Survey for Site 10, Hudson River Re clamation Project, Abstract, Albany, New York. HONS 009478 Hudson River Reclamation Project Stage 1 Cultural Resource Survey for Site 10 Abstract A cultural resource survey was conducted at the proposed PCS con tainment site (site 10) In the town of Fort Edward, Washington County -tt New York for the purpose of Identifying historic and/or prehistoric resources that could be Impacted by the proposed action. This Stage 1 ' survey Included a literature review, sensitivity model for predicting areas likely to contain previously undiscovered resources, and systematic field Investigation. As a result of this study, thirteen (13) cultural resources were Identified In the proposed project area. A Stage 2 cultural resource survey Is recomnended for the purpose of evaluating the potential eligibility of selected resources for listing on the National Register of Historic Places. These resources include two (2) prehistoric sites and an old barn complex. It Is recomnended that Impact be avoided to the west bank of the Oead Creek, an archeologically sensitive zone. Also, mitigating measures will be developed to minimize potential Impact to the Old Champlain Canal, a property listed on the National Register. B- 1 HONS 009479 APPENDIX C PCB Settlement Agreement Between the New York State Department of Environmental Conservation and General Electric Company, September 8, 1976 New York Department of Environmental Conservation, 1976. PCB Settlement Agreement between the New York State Department of Environmental Conservation and 6eneral Electlc Company, Albany, New York. HONS 009480 STATE OF MEW YORK DEPARTMENT OF ENVIRONMENTAL CONSERVATION IN THE MATTER OF ALLEGED VIOLATIONS OF U 17-OSOT, 17-0511 and 11-0503 OF THE ENVIRONMENTAL CONSERVATION LAW OF THE STATE OF NEW TORE BT: GENERAL ELECTRIC COMPANY, Respondent* 1 2 Flic No. 2833 . .' AGREEMENT Die following Is the agreement aide between the Department of Environmental Conservation (Department) and General Electric Company (General Electric) on Septanber , 1976 to settle this proceeding: (1) This agreownt is based upon the mutual conviction that It Is in the public Interest to terminate this proceeding and voluntarily Undertake forthwith the cooperative programs provided for In this agreaeent without further de'.ay. . (2) Thfj proceeding was commenced on September 8, 1975 and hearings began before Abraham 0. Sofaer, Esq., the duly designated hearing officer, on October 6, 1975. An Interim opinion was rendered by the Hearing Officer oo February 9, 1975. Hearings resuaed on April 19, 1976 and the record is now complete. All parties have >rJefed the Issues and the briefs have been submitted to the Hearing Officer. HONS 009481 - ' (3) *(a) As Its full share of a comprehensive program of at laast $7,000,000 to deal with- PCBs In the Hudson River and related cnvlroimwntal concerns. General Electric will within sixty (GO) days of the date of this Agreement contribute $3,000,000 In a lump sua to the Department and In addition. General Electric will perform $1,000,000 In research, making the benefits of the research available to the Department, as specified In Exhibit 1. The I. Department will participate In the-comprehensive program In an amount comparable to General Electric's cash contribution by the expenditure of finds legally avallabla to It and In conjunction with Its mandated duties. (b) General Electric's $3,000,000 contribution shall be used by the Department, 4 In Its discretion, as 'Gen1eral Electric's share of a program * of at least $6,000,000 to: (1) monitor the presence and levels of PCBs which . * * have been discharged In Hudson River waters In water, sediments and biota; (11) further Investigate the need for remedial action concerning PCBs present -In the Hudson Rtver; (111) Implement remedial action. If necessary to protect- public health and resources, concerning PCBs present In the Hudson River; (1v) ' aid In developing a program to regulate the storage and discharge of substances hazardous to the environment If sufficient mongys are available after implementing remedial action concerning PCBs. (e) The Commissioner of Environmental Conservation (Commissioner) will establish an advisory conalttee consisting of Independent experts, govern mental,- and private Interests which will, at regular "meetings, review and make public recosnendatlons to the Comalssloner concerning the scope, content, progress and results of the programs, studies and expenditures for which provision Is made In paragraph 3(b). In addition, the Department will furnish the advisory cornelttee with'aiy Interim report(s) and final report(s) of the research described In Exhibit 1. The advisory cored ttee will continue to function throughout the comprehensive program concerning PCBs and related environmental concerns. MOMS 009482 C-2 HONS 009483 lapla shall thM t fhi s such p Depart appllc feads ally. tn tte the e SUtt c Mudsaa Faeillt dtsefear flfty-f Mrtr ^ Manefar MStMl (u hart tnngt Per'day (10) gra point so provided, however,'that if General lettj ic,can demonstrate that by the ' operation of. the facilities described In the Crawford and Russell Report. and all reasonable ncdlflcations thereto, such effluent levels cannot be achieved, then 6cnera1 Electric trill be permitted to discharge such average and mxImi amount of PC8s as are achievable by the operation of said facilities, but. In any event, no greater than a dally maxima discharge of 0.11 pounds (fifty (50) grans) of PC9s Into the eaters of the Hudson Rlvw. (b) The goal-of the Department and the Natural Resources Defense Council, Inc. is the complete elimination of all PCS discharges. - ' (c) General Electric will continue to review PCS treatment - systems and Install such systcm(s) at Its Capacitor Manufacturing Facilities as may be necessary to comply with the requirements of Sections 301 and 307 of the Federal Water Pollution Control Act Aewndaents of 1972, ' _ . (7) General Electric v11T'continue Its dally monitoring of the total amount of discharges of PC8s reaching the Hudson River from-all point sources or discharge outlets at Its Capacitor Manufacturing Facilities. The general conditions for General Electric's program are as follows: (1) hourly samples are composited for each discharge for each twenty-four (2d) hour period In proportion to flow; (11) the results of the analysis for PCSs in each * composite dally sample for each week are submitted to the Department and the United States Environmental Protection Agency, Region II, within one (1) week of the close of each calendar month. . . " (8) Within thirty (30) days of the date of this agreement. General Electric will submit to the Department final plans and specifications for waste treatment and discharge control facilities described In the engineering report prepared by Crawford and Russell, Inc., dated February 20, 1976 and an addendum thereto dated April 7, 1976 (the "Crawford and Russell Report") and after approval of the final plans and specifications which will be Issued within sixty (60) days after submission Install and cause said facilities to be operational within five (5) months of such approval. MQNS 009484 V (9) The Department reserves the right by legal- procedures for modification of General Electric's SP0E3 or NPOES permits, and pursuant to applicable provisions of law, to require that General Electric achieve aore stringent Imitations on the. discharge of PCBs or take any additional action to further reduce the discharges of PCBs froai any point source at Its premises and facilities located at Hudson Falls and Fort Edward, New York, "(10)-The-provisions of this agreement or the order for which It provides, shall not constitute or be construed as an adjudication or finding * on any Issue of fact or law, or evidence or adalsslons by any party with respect to any Issue In this proceeding, or be construed as, or operate as, an adal salon that General Electric has violated any law or regulation or other- vise ccnaritted a breach of duty at any tine, and shall not constltut. in this - proceeding or any other proceeding or litigation or otherwise, any evidence * or Implication of any such violation or breech of duty. No amount of the settlement contribution by General - Electric constitutes a fine or penalty. . (11} (a) General Electric's acceptance of the provisions, tenes and conditions of this agreement shall be In full and complete satisfaction and release of each and every claim, demand, remedy or action whatsoever against General Electrlc.lts offlcers.'dlrectors, employees or agents which was or might have been alleged or encompassed within the original or wended - complaint In this proceeding, or which the Department may have, relating to or arising from General Electric's direct or Indirect discharges of PC8s reaching the waters of the Hudson River from General Electric's premises In Hudson Falls and Fort Edward, New York, Including future discharges permitted by-this agreement or the order for which the agreement provides. _ (b) This release shall Inure only to the benefit of General Electric, Its officers, directors, employees, agents, successors and assigns, at law or In equity, with respect to the aforesaid ratters. HONS 009485 C-5 (c) Notiling herein-shall be construed as barring. diminishing, adjudicating or In any nay affecting any legal or equitable rights or elate, actions, suits, causes of action or demonds whatsoever that the Department will have against anyone other than General Electric, its officers, directors, employees and agents. ' (12) The right of the Department undar law to enforce the terns of this sgreamnt shall not be affected by any release contained herein. ' . (13) An Order In the usual fora and containing all of the provisions of paragraphs 5, 6, 7, 8 and 9 of this agreement should be entered In final and complete disposition on the merits of this proceeding. It is hereby sttpulat ed that the Hearing Officer nay recossnend and the Coamissloner of '* . Envlroneental Consorvetlon may Issue the Order. t - (14) This agreement, together with Its exhibits, constitute the entire agreement between the Department and General Electric concerning ' the rights and obligations herein provided. . HONS 009486 6V. The parties hereto have, executed this sett! went agreement this day of Septeaber, 1976. . . it GENERAL ELECTRIC C0MPANV ' \MjL Welch, Vice President and Group Executive DEPARTMENT OF ENVIRONMENTAL CONSERVATION bv Peter A. A. Bari*. Coanlssioner HONS 009487 C-7 EXHIBIT I Cmrtl Electric grants to the Department of Environmental Conservation the non-exclusive right to uso the results of the following research: *' A. General Electric will conduct research. Itself-or by contract, on the.environmental comparability of Its substitute non-PCS dielectric 'capacitor fluids. .The research expenditures will be not less than $400,000 .of which $400,000 shell be applied to the. General Electric $1,000,000 research canaitmant set forth in paragraph 3(a) of the foregoing agreement. ' . ' The research shall consist of chemical and biological tests selected by. General Electric freer the following:. . .- Acute Oral Toxici^r (rets) Acuta Dermal Toxicity (rats) Skin A Eye Irritation (rabbit) Acuta Toxicity (fresh water fish) Subacute Toxicity (fish) Water Solubility '. Partition Coefficients 28 Day Rato feeding Ames Test - screening test for card nogen1 ty Acute .Toxicity (birds) Bloeccunulatlon (fish) Biodegradation (CRO) Acute Inhalation (rats) Soil Migration . Vaporization Rata Soil Biodegradation Soil Organism Toxicity Acute Toxicity (marine) Toxicity to fish Eggs A fry River Oie-eway 90 Day Rate feeding Decomposition Products Subacute Toxicity Tests Chronic feeding Studies B. General Electric, Itself or by contract, will conduct research and pilot plant studies to be-approved prior to being undertaken by the Conetssloner after his consultation with the advisory comnlttee on the removal or treatment of PCBs In supernatant liquids and sediments from Hudson River sludge dredged by the Department and delivered by It to the General Electric prmalses at fort Edward. The expenditures for research and pilot plant shall be $400,000, all of which shall be applied to the General Electric $1,000,000 HONS 009488 research canal tment sat forth In paragraph-3(a) of the foregoing agreement. Iha research and pilot plant studies shall consist of tests of physical, chemical and biological Mans for.the removal and treatment of PCSs. C. General Electric will conduct research. Itself or by contract, as specified by the Comrissloner of the effect on the environment of not more than-three (3) substances which nay be hazardous to the envlroneent and which, are to be selected by the Comalssloner after his consultation with tha advisory committee. - . The research expenditures will total $200,000, all of which shall be applied to the General Electric $1,000,000 research coenribnent set forth Ip paragraph 3(a) of the foregoing agreement. The research shall consist of chcorfcal and biological tests selected by the Cotmlssloner. The term 'expenditures* shall mean amounts paid for Independent contractors, equipment, supplies, standard consulting fees to other C. Z. components and actual salary cost plus normal overhead and earglns. HONS 009489 C-9 STATE OF NEW TORE DEPARTMENT OF ENVIROIWENTAL CONSERVATION BTHE NATTER OF ALLEGED VIOLATIONS OF 17-0501, 17-0511 and 11-0503 OF THE ENVIRONHBITAL CONSERVATION LAW OF THE STATE OF NEW TORK BY GENERAL ELECTRIC COUPANY, . Respondent. . ' .' ` . ' FINAL ORDER ' . _ ' . ' .' . RECITALS . . 1. This proceeding ms conuenced by the Department of Envlranentel . Conservation (Department) on Septzaher S, 1975 by service of a notice of hearing and verified complaint upon Respondent, alleging .Respondent's violations of ECE Sections 17-0501, 17-0511 and 11-0503 by reason of Its discharges of PC3* Into the Hudson River. The Respondent filed a verified answer denying the alleged violations. ' 2-. The New York State Department of Commerce ("Caanerce"), . Associated Industries of New York Inc. ('Associated*} and the Natural Resources Defense Council Inc., the Hudson River Fisherman's Association, Inc., the Hudson River Sloop Restoration, Inc. and the Federated Conservationists of Westchester County, Inc. (collectively *NRDC*} were permitted to Intervene as parties.' . _______ 3. The hearings In this proceeding commenced on October 5, 1975 before Abraham D. Sofaer, a duly designated hearing officer. The Department appeared by Philip H. Gltlen, Esq., its counsel; the Respondent appeared by Bond, Schoeoeck t King, Its attorneys, N. Earle Evans, Jr., Esq., Anthony R. Plttarelll, Esq., John F. Repko, Esq., and Arthur V. Puccini, Esq', of counsel; . HONS 009490 C-10 Canr: appeared by 0. Bruce McDonald, Esq., Its former counsel end HIduel Curley, Esq., Its present counsel; Associated appeared by Costello, Cooney and Fearon, Its attorneys, Oonald l. Nicholas, Esq., of counsel; ' and NRDC appeared by Sarah Chasls, Esq. and Rosemary Nichols. Esq., Its counsel. . - 5; An Interim opinion ms rendered by the Hearing Officer on February 9, 1978..' Hearings resmsed on April 19, 1976, and the record Is now complete. All parties have briefed the Issues and the briefs have been submitted to the Rearing Officer. . 6. Respondent and the Department hays'entered Into a settlanent agreement dated Septmeber y , 1976, In which It mss agreed that this order ay be made. 44 4 7. The Hearing Officer has found that" the settlement agreement end this order are In the public Interest and has recommended that they be -executed by the Commissioner of Environmental Conservation. NOW, after full consideration and upon all of the proceedings and being duly advised. It Is ORDERED that: I. On and after the date of this Order, the discharges of PCBs Into the Hudson River from Respondent's premises and facilities located In Hudson Falls and Fort Edward, New York, which cause or contribute to the contravention of the weter quality standards adopted for and assigned to the waters, receiving Respondent's dlschargesTsJtaTl constitute violations of this Order as well as violations of tho Environmental Conservation Law of the State of New York and the rules and regulations proaulgatad under It; provided, however, that no action or proceeding for penalties or for any remedy or relief whatsoever, for any-such violations shall be Instituted by the Department for so long as Respondent adheres to and cosipltes with the provisions, terms and conditions of this Order and proceeds w' '----- >'.* HONS 009491 Its wetar pollution abatement program In accordance with the provisions, torn and conditions of Schedule A which Is attached and incorporated hr* reference. The Department reserves the right, however, by legal procedures for Modification of General Electric's SPDES or NPDE5 permit and pursuant to appli cable provisions of law, to require that General Electric achieve norm stringent limitatlonscon the discharge of PCSs, or take any additional action to further reduce the discharges of PCSs from any point source at Its premises and facilities located at Hudson Falls and Fort Edward, New York. ' II. All reports and submissions required by this Order shall be made.to the Director of the Division of Pure Waters of the Department In' Albany, New York. All time limits set forth in Schtdule A shall caneence on the data the conformed copy of . this Order Is served upon Respondent. ,, ' III. To Insure compliance with this Order, duly authorized repre- sentzttves of the Departaent shall be permitted access to Respondent's 'premises and facilities for the purpose of Inspecting them and for the purpose of making or requiring such tests as may be deemed necessary. Including sampling of discharges and receiving waters, tn determine the status of oaplianct with the provisions, terms and conditions of this Order. IV. Respondent shall not suffer any penalty under any of the provisions of this Order, or be subject to any proceedings or actions for any remedy or relief. If It cannot comply with any requirements of the Order because of an act of God, war, strike, riot, catastrophe_or-ther condition as to which negligence or willful misconduct on the part of the Respondent was not the proximate cause, provided that the Respondent shall notify the Comrlssloner In writing within a reasonable time after It obtains knowledge of the facts and requests an appropriate extension or modification of this Order. ' C-12 HONS 009492 . V. The provisions, tana and conditio** of deemed to bind Respondent, Its officers! directors, a successors, and assigns and all persons, fins and cn or for It. n. By this order, this proceeding Is flea terminated on the aerlts. Datedr Albany, New York September ^ ,1976 PETES A. A. New York Sts Esalrw--ft TO: GENERAL ELECTRIC COMPANY Electronic Components __ Business Division ' Electronics Pirk Syracuse, New York 13201 HONS 009493 SCHEDULE A 1. Respondent, after the dete of this Order, shall not discharge a monthly avenge greater than four hundred fifty-four (454) grass (one (1) ' * pound) of PCBs per day 'a reaching the ' waters of the Hudson River fns all' point sources or discharge outlets fros Its facilities and prealsas located In _ Hudson* Falls and -Fort Edward, New York. . i 2. Respondent shall., within sixty (SO) Ays after the wastewater trealsant facilities described In the Crawford and Russell Report (as herein after defined) are Installed and aide operational, achieve a aoathly average discharge of no grantor than 0.0022 pounds (on* (1) gran) of PCBs par day and a dally aaxlnai discharge no greater than 0.022 pounds (ten (10) gnus) of PC>s per day reaching the waters of tho Hudson River from all point sources - or discharge outlets fron Its facilities and premises located In Hudson Fallr and Fort Edwaed. How York provided, however, that If Respondent on danoastrate .that by the operation of tho facilities described In the CrawAird and'Russell Report, and all reasonable modifications thereto, such effluent levels cannot be achieved, then Respondent shell be permitted to discharge such average and maximum amount of PCBs as are achievable by the operation of sa'ld facilities, but. In any event, no greeter than a Ally maxim* discharge of fifty (50) ' grass of PCBs Into tho waters of tho Hudson River-. -- ' . 3. Respondent shall continue Its Ally monitoring of tho total amount of discharges of PCBs reaching the Hudson Rlver-frcm ell point sources . or discharge outlets at Its premises end facllltles-located In HuAon Falls and Fort Edward, New York. Hie general conditions for Respondent's program shall .be as follows: (1) hourly samples shell be composited for each discharge for etch twenty-four (24)'hour period In proportion to flow; (11) the results of - the analysis for PCBs In each composite Ally sample for each week shell be submitted to the Department and the United States Environmental Protection Agency, Region II, within one week.of the close of each calenAr.'conth. c-i* HONS 009494 4. Within thirty (30)' days of tho data of this Ordtr, Respondent shall submit to tha Department final plans and specifications for waste . treatment and discharge control fadlltlas described In the engineering ' report prepared by Crawford and Russell* Inc., dated February 20, 1376, and-ajuddandiauthareto-datad April 7, 1976 (tha "Crawford and Russall .' Report")-and after-approval, of tha final plans and specifications install and causa said-facilities to be operational within five (5) ninths of such approval-. MOWS 009495 I sains aria SrovIMIt conditions Dated: Alt STATt OF SB counroF* <XMA F. VBX say ttat A* v, a V1c Frcsf x corporation h* is utter HONS 009496 STATE OF NEH TORE *-- department of enyirotciehtal conservation IN THE MATTER OF ALLEGED VIOLATIONS OF 1117-0501, 17-0511 and 11-0503 OF THE ENVIRONMENTAL CONSERVATION LAV OF THE STATE OF NEW YORK BY: GENERAL ELECTRIC COMPANY, Respondent File No. 2833 STIPULATION - ' IT IS HEREBY STIPULATED by and between tlie Attorneys for the Respondent and the Counsel for the New York State Department of Environmental Conservation that sufficient facts e::1st in all of the proceedings to date herein upon which the proposed Order attached hereto my be predicated and that such Order may be made, filed and entered by'the Commissioner cf Environmental Conservation of the State of New York. m r.f.WBOWNMOW,I WSCIMHMObEWNWEC<WK & KiuINnGv Attorneys for Respondent General Electric Company Dated: Albany, New York September ? ,1976 T iVltfi, Assistant counsel New York State Department of Environmental Conservation HONS 00949 7 APPENDIX D Federally Listed or Proposed Endangered or Threatened Species In the Hudson River, Hudson River PCS Reclamation Demonstration Project Chupp. Norman R. (written communication) July 20, 1981. Letter from Norman R. Chupp, Area Manager, United States Department of the Interior, Fish and Wildlife Service. Harrisburg Area Office, Harrisburg, Pennsylvania, to Stephen Arella, Chief, Environmental Impacts Branch, U.S. Environmental Protection Agency, New York, New York. -- Peterson, Allen E. Jr., (written coenunlcatlon) July 24, 1981. Letter from Allen E. Peterson, Jr., Regional Director, United States Department of Commerce, National Oceanic and Atmospheric Administration, National Marine Fisheries Services, Gloucester, Massachusetts, to Stephen Arella, Chief Environmental Impacts Branch, U.S. Environmental Protection Agency, NY, NY. MOMS 009498 UNITED STATES DEPARTMENT 6F THE INTERIOR FISH AND WILDkIFE SERVICE---- HARRISBURG AREA OFFICE 100 Chestnut Strati, Room 310 HarrftOurg, Pennsylvania 17101 JUL i 0 1981 Nr. SUphtn Y. Aralla. Chief Environmental Impacts Branch U.S. Environmental Protection Agency 26 Federal Plaza New York, New York 10278 Dear Hr. Arella: This responds to your letter of July 17, 1981, requesting Information on the presence of federally listed or proposed endangered or threatened species within the Impact area of the proposed Hudson River PCS Reclamation Demonstration Project, New York. Except for occasional transient species, no federally listed or proposed species under our jurisdiction are known to exist In the project Impact area. Therefore, no further Section 7 consultation under the Endangered Species Act Is required with the Fish and Wildlife Service (FWS). Should project plans change, or If additional Information on listed or proposed species becomes available, this determination may be reconsidered. This response relates only to endangered species under our Jurisdiction. It does not address other FWS concerns under the Fish and Wildlife Coordination Act or other legislation. A compilation of federally listed endangered and threatened species In New York Is enclosed for your Information. Please note that the osprey Is not listed. Because the shortnose sturgeon Is not under our jurisdiction, requests for Information should be directed to: Mr. Douglas W. Beach, National Marine Fisheries Service, 7 Pleasant Street, Gloucester. Massachusetts 01930. Sincerely Enclosure Norman R. Chupp Area Manager 'jnr r j* ffiu.c! HONS 009499 UNITED STATES DEPARTMENT OP COMMERCE Federal Building H Elm Street Gloucester, Massachusetts 01930 JUL 24 1901 Mr. Stephen Arella Chief, Environmental Impacts Branch U.S. Environmental Protection Agency Room 1400 26 Federal Plaza New York. New York 10278 _ Dear Mr. Arella: This Is In response to your July 16, 1981, request for evaluation of the adequacy of statements made In your Draft Environmental Impact Statement (DEIS) on the potential effects of the Hudson River FCB Reclamation Demonstration Project on the endangered shortnose sturgeon (Aclpenser brevlrostrum). He have reviewed the DEIS and agree that shortnose sturgeon currently encounter, and are likely to accumulate high levels of chemical pollutants. Including PCB's, from the Hudson River. He also concur with.the statement In your letter that shortnose sturgeon will ultimately benefit from the proposed action, provided dredging does not take place at a time and loca tion where either adults spawn or larval and juvenile stages congregate to feed. The current knowledge of habitat usage by shortnose sturgeon In the Hudson River Indicates that these essential areas are all located below the "hot spots* Identified for dredging In the DEIS. Therefore, we believe that the proposed project will have no adverse effect on shortnose sturgeon In the Hudson River and that further formal Section 7 consultation on this matter is unnecessary at this time. Should project plans change or new Information become available on the temporal and spatial distribution of the species that would alter the basis for our decision, consultation should be continued. Sincerely Allen E. Peterson, Jr. Regional Director HONS 009500 APPENDIX E Concentration and Public Health Significance of Cesium 137 In the Proposed PCB Containment Facility The material In Appendix E was prepared by HAPORA, Inc. HONS 009501 APPENOIX E CONCENTRATION AND PU8LIC HEALTH SIGNIFICANCE OF CESIUM 137 IN THE PROPOSED PCB CONTAINMENT FACILITY TIm trace Mounts of radioactive fallout products that will be present in the containment site will not have any public health significance. The radio active Materials Mill be present at extrenely low concentrations and Mill be dispersed In the contained sedlnents. In addition, radioactive enlsslons that are produced will be largely absorbed by the clay cap on the site. This can be shown by estlnating the Mount of ceslun that will be present at the site and the Mount and type of radiation that will be enitted. The Mount of ceslun that would be present In the site under the reduced scale progrM can be roughly estimated as follows: a. Volume of sediment on the site * 0.5 x 10s cu yds Sediments will be dredged to approximately 3 ft deep, but cesiua 137 Is generally found at sediment depths of less than 2 ft. Only the volume of material actually containing ceslun 137 need be considered (Sanders, PC8 Settlement Advisory Committee, June 26, 1981). b. Mass of Sediment per unit volume 0.8 x 10 g/cu yd This is based on a specific gravity of 2.56 for quartz (SlOg), which Is the main type of material comprising the dredge spoils. Because the volume estimates are for wet sediment, the water content of the sediawnt must be taken Into account, and the actual mass Is much less (65 lbs/cu ft) (Sanders, PCS Settlement Advisory Committee, June 267* 1981). E-l HONS 009502 c. Approximate concentration of cesium 137 - 0.3 plcocuries (pci) per grae A mean value of 0.3 pci per grae of sediment Is a reasonable estimate of the concentration of cesium present, based on previous analyses (Sanders, PCS Settlement Advisory Camalttee , June 26, 1981). d. Thus, the amount of cesluo 137 that Mould be placed In the contalnawnt site Is 0.3 pcl/g x 0.8 x 10 g/cu yd x 0.5 x 10 cu yd 1.2 x 1011 pci 0.12 curies (cl) The public health significance of 0.12 cl of cesium 137 In the containment site can be shown as follows: a. Radioactive decay of ceslua 137 Cesium 137 has a half-life of approximately 30 years and decays yielding: 1. beta particles with maximum energy of 1.176 million electron volts (aev) (7 percent of the time) and 0.514 aev (93 percent of the time). 2. two moderate energy electrons 3. gmema ray with eneray of 0.662 mev (85 percent of the time). b. Estimate of the exposure of surrounding area to the radioactive decay products of cesium 137 for ease of computations, all the activity will be assumed to be concen trated at a single point, closest to the nearest house. Actually, the activity will be spread throughout the site, thus reducing the exposure. The E-2 HONS 009503 average background exposure due to natural radioactivity Is 125 nilllrast (araa)/year (yr), with a range of 100 to 250 area/yr (United States Oepartaent of Health. Education and Welfare [USOHEW, 1970]). 1. Beta Particles - As a conservative estimate, only the highest energy particle (1.176 aev) will be considered, even though It Is generated only 7 percent of the time. The range for beta of this energy would be 460 ag/sq cm (USOHEW, 1970). The density of air Is 1.293 x 10*3 g/cu cm. The distance (d() the part.1ples would travel In air Is: d# - 460 mg/sq cm x 1/1.293 mg/cu cm 356 cm or 3.6 a Since the cesium Is found In the sediments with a density of approx1metely 2.56 g/cu cm, the distance (d$) that the particles would travel In the sediment Is : d$ 460 mg/cu cm x 1 0.18 cm ZITTT? mg/cu cm Thus, the beta particles will not be able to penetrate the clay cap and be aaltted from the containment site. Similarly, the moderate energy electrons would also be confined to the site, posing no public health concern. 2. Gamma Emission For an unshielded point source, using the /"* constant method, the dose rate (DR) (s given by equation (1) (USOHEW, 1970): (1) OR -,/"1 A/r2 where,/-1 Is the ray constant which equals 3.3 R / hr cl E-3 HONS 009504