Document jyma5j7LBOzEozXzmVwzX2yR

DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR THE HUDSON RIVER PCB DEMONSTRATION RECLAMATION PROJECT May 1981 Prepared by: U.S. Environmental Protection Agency - Region II Cooperating Agencies: U.S. Army Corps of Engineers New York State Department of Environmental Conservation Abstract: This environmental Impact statement (EIS) has evaluated the proposed Hudson River PCB Reclamation Demonstration Project from the standpoint of public health, environmental Impact, coat, and engineering feasibility. As a result of these analyses, U.S. Environmental Protection Agency (USEPA) recommends that the action alternative be Implemented. The full scale action alternative estimated at approximately $43 million dollars has been determined to be the most desirable project in terms of potential beneficial impacts. However, since the full scale project may not be realised unless additional funds are obtained by New York State Department of Environmental Conservation (NYSDEC), the reduced scale project is also recommended. As a part of the action alternative the development of a monitoring program is recommended to demonstrate any Improvement in the rate of recovery of the Hudson River and the feasibility of the indefinite storage of PCB con taminated sediments In an upland containment site. EPA has determined that this actloa with the mitigation measures described in the EIS, will not endanger public health, safety, and welfare. The alternatives discussed in this draft EIS for the proposed Hudson River PCB Reclamation Demonstration project Include: the no-action alternative (with and without future maintenance dredging); control of river flow; in-rlyer detoxification; dredging alternatives; remnant deposit alternatives In the area of the former Fort Edward Dam; and full scale or reduced scale dredging program with in-rlvtr containment. These alternatives are evalu ated to determine both their feasibility and Impact on the environment. This National Environmental Policy Act (NEPA) draft EIS is based largely on the NYSDEC's State Environmental Quality Review Act draft EIS and supporting documents. Significant Impacts which were further evaluated in this NEPA draft EIS include primary and secondary impacts on public health, fisheries, maintenance dredging and navigation, and agriculture. MOMS 009755 -2- Publlc Hearings: June 23, 1981: 7:00PM Washington County Courthouse Route 4 and Maple Road Hudson Falls, New York June 24, 1981: 7:00PM Dutchess County Community College Dutchess Theater Pendell Road Poughkeepsie, New York June 25, 1981: 6:30PM 2 World Trade Center Main Hearing Room - 44th floor New York, New York Approved by: Contact for Information: Ms. Robin Rohn U.S. Environmental Protection Agency - Region II Environmental Impacts Branch 26 Federal Plaza, Room 400 New York, New York 10278 (212) 264-8677 RicTJarf T. Dewllnaf Ph.D. Acting Regional Administrator HONS 009756 EXECUTIVE SUMMARY DATE: TYPE OF STATEMENT: RESPONSIBLE FEDERAL AGENCY: TYPE OF ACTION: May 1981 Drafe (J.S. Environmental Protection Agency (EPA) * Region II Adrainistrative RECOMMENDED ACTION Based on public health, environmental, cost, and engineering evaluations carried out by EPA and its environmental consultants, the EPA recommends 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 projact. Modifications and contingencies developed will be submitted for public comment 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 (PCB) hot spots be implemented. After carefully evaluating both the original full-scale proposal and reduced-scale propose! submittted by New York State Department of Environmental Conservation (NYSDEC), EPA recommends funding a modification of the original full-scale project, since greater po tential benefits will be realized. However, if additional funding ia not available, the reduced-scale project is also recommended, although it offers only s 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 Clesn Water Act (CWA) Amendments is $20,000,000. If the action alternative is MONS 009 75 7 S-l Table S-l EPA Recommended Program Full- Scale Reduced-Scale Dredging or in-river containment of all 40 hot apot areas in the river bed with containment in a secure upland site. Design and construction of a secure upland containment sice capable of indefinite long-term isolation of contaminated material Deletion of remnant deposit removal and upland containment; instead, provision of secure cap and top dressing,and further bank stabilisation if necessary Elimination of provision for the con tainment of PCB-contaminated material from dumpaitea in the Fort Edward area. Provision for containment of contaminated materials from three New York State Department of Tranaportation (NYSDOT) dredge spoil sites (212, 13 and 204 Annex) Provision for dredging end containment operational standards and procedures, mitigation measures, monitoring progrmna, and contingency plena necessary to safe guard public health and agricultural resources Provision for research studiea/anvironmental monitoring programs necessary to demonstrate the improvement in the rete of recovery of the river and storage of contaminated material Reduction of the number of Hoc 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 009758 approved, Che recommended action is Co undertake the originally proposed $40,000,000 full-scale project with the required modifications. Additional funds from either federal, state, or perhaps outside sources will be required to implement 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 recom mended that the $26,700,000 reduced-scale project could be undertaken along with the aforementioned project modifications. 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, they have been used principally in electrical transformers and capacitors, but they have also been used in a variety of other products including lubricants, pesticides, cutting oils, plasticizers, and adheaives. During a thirty-year period ending in 1977, over 227,000 kilogrmaa (kg) (300,000 pounds [lb]) of PCBa were discharged into the Hudson River from two General Electric (G) capacitor manufacturing plants at Fort Edward and Hudson Falls, New York. Much of the discharged PCBs was adsorbed by the bottom sedi ments of the river and accumulated behind the Fort Edward Dam. When the dam waa removed in 1973 due to its deteriorating condition, a large amount of the PCB-coneaminaced 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 Edvard to New York Harbor. PROJECT DEVELOPMENT BY NYSDEC As part of a court settlement between NYSDEC and GE, approximately $3,000,000 waa spent by NYSDEC to investigate the extent of PCB contamination in the Hudson River and methods to reduce and remove Che threat of continued PCB contamination. Forty PCB "hot spots" have been identified in the upper Hudson River, baaed on five years of scientific and engineering studies. Hot spots have been defined as sediments containing SO aicrograme per gram (ug/g) (parts per million [ppm] ) MGNS 009759 S-3 or more of PCBs. PCB concentrations along the depositional shore range from 5 to 1,000 ug/g (ppm) in fine grained sediments. In addition, five PCB-contsminated remnant deposits have been identified. Remnant deposits were formed by as a result of the removal of the Fort Edvard Dam, which caused water levels of the river behind the dam to drop significantly. This caused once-submerged bottom sediments to be exposed to the atmosphere. At present, PCB concentrations in the remnant deposits range from SO to 200 ug/g (ppm). The investigations conducted by NYSDEC resulted in a project which proposed to demonstrate the feasibility of removing PCB-contaminated sediments from the upper Hudson River and deposit those sediments in a secure upland containment site. The environmental analysis, costs, engineering, and feasibility of the project proposed by NYSDEC are presented in a draft environmental impact state ment (EIS) prepared in accordance with Che 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, NYSDEC rescoped the originally proposed project to accommo date the $20,000,000 funding authorized by the amendments to the Clean Water Act (CWA) (Sections 116(a) and (b)] and State matching funds. The reduced-scale project, as developed by NYSDEC, would cost $26,700,000. A comparison of the full- and reduced-scale projects is presented in Table S-2. CONGRESSIONAL 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 hsve 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 demonstration/reclamation project for removing and disposing of PCB-contaminated sediments from the Hudson River. Section 116(a). The Administrator is authorized to enter into contracts and ocher agreements with the State of New York to carry out a project to demonstrate methods for the selective S-4 HONS 009760 Table S-2 NYSDEC Recomnended Program Full-Scale Dredging of all 40 hoc spoC areas in the river bed wich containment in a secure upland site Design and construction of a secure upland containment site capable of long-term isolation of contaminated material Excavation of two remnant deposits (areas 3 and 3) located above the former Fort Edward Dam site, and removal to the upland containment site Provision for containment of material from three PCB contaminated dump sites (old Fort Edward, Fort Hiller and Caputo) should removal be found more suitable than in-place containment Proviaion for containment of con taminated materials from three IfYSDOT dredge spoil sites (212, 13 and 204 Annex) Destruction of the recovered PCBa 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 number 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 remnant deposit removal and upland containment; instead provision of top dressing and fencing for remnant deposits 3 and 5 Elimination of provision for the containment of PCB-contaainated material from Old Fort Edward, Fort Miller and Caputo dump sites. Same Same Reduction in the level of funding for research studies S-5 MQNS 009761 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 watervay. 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 vouLd 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 coat 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 datermined 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 shell 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 aaaist 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: selective removal of PCB-contaminated sediments from the Hudson River creating the contaminated sediments as required and burying those sedi ments in a secure landfill 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 s secure landfill the Administrator of EPA must first determine that the S-6 MONS 009762 placement of the pollutants in a secure landfill would provide a higher degree of protection of public health, safety, and welfare than either leaving the PCBcontaminated sediments in place or disposition by any other methods. In addi tion, before funding under Section 116 of the CWA can be provided, the Admini strator of EPA must determine that funding is not available under Sections 115 and 311 of the Act, aa well as any existing "Supecfund" 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 1960, Congress authorized EPA to make grants to the NYSDEC in order to carry oue the intent of the "Hudson River PCB Reclamation Demonstration Project." On January 12, 1981 EPA-Region II issued a Notice of Intent (NOI) to prepare an EIS. The purpose of NEPA is to identify and analyze any potentially significant impacts on the quality of thehuman environment resulting from a proposed project. In addition, the NEPA EIS decision-making process provided the forum for soliciting public comments on the proposed project by conducting s series of public meetings and hearings. A twenty-one member Citizens Advisory Commietee (CAC) has been formed to advise EPA on issues of public concern regarding ehe project. As stated in the NOI, it was EPA's intent to further evaluate the following in the NEPA EIS: e no-action alternatives e control of river flow e in-river detoxification in-river contamination remnant deposit alternatives in the area of the former Fort Edvard Dam e complete or partial dredging, combined with upland containment dredge spoil disposal and treatment options s other alternatives concerning PCB removal, including alternative dredging and transport S-7 HONS 009763 These alternatives were evaluated for potential beneficial and adverse, short- and long-term 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 bioaccumulation of PCBs through the food web. 4. Protection of wetlands C. Maintenance Dredging and Navigation 1. Mitigation of future maintenance dredging and disposal problems 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 remmant 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 S-8 HONS 009764 FINDINGS OF THE NEPA EIS 1. Disposal of PCB-contaminated dredge spoils in a landfill would provide a higher standard of protection of the public health, safety, and welfare than disposal of auch pollutants by other methods including, but not limited to, incineration or a chemical destruction process. The basis of the above conclusion is that alternative disposal methods are either infeasible or highly speculative and would render the entire project economically infeasible within the amounts of money available for the "rescoped" project (i.e., $26.7 million). 2. The proposed containment site, incorporating the modifications and safeguards described below, is environmentally sound for indefinite storage of PCB-contaminated sediments. The storage of contaminated sediments at the proposed containment site will not cause significant long-term adverse environmental impacts to the surrounding communities. 3. The proposed dredging operation, incorporating the modifications and safeguards described below, will not have significant short- or long term adverse effects on the surrounding community, downstream water supplies or the ecology of the Hudson River. 4. Removal and in-river containment of substantial quantities of PCB-laden sediments should demonstrate an improvemant of tha rate of recovery of the Hudson River. 5. Removal and in-river containment of PCBs from the upper Hudson River will also reduce the risk of: - contaminating downriver water supplies caused by high flow conditions - public health threats due to excessive volatilisation from the river bank areas - public health threats due to the consumption of contaminated fith - the necessity to close the Hudson River fishery due to high flows after projected reopening - permanent closure of the striped bass fishery - conducting environmentally unsound maintenance dredging and upland diapoaai of contaminated sediment from the upper Hudson River and estuary - closing navigable waterways both in the upper and lover Hudson River due to the inability co provide adequate upland containment of containment dredge spoil - endangering aquatic species, in particular Che shortnosed sturgeon HONS 009765 S-9 6. Removal and in-river containment of PCBa from the upper Hudson River is not expected to significantly reduce PCB sediment concentrations in the New York Harbor. 7. As presently proposed by NYSDEC, PCB volatilization caused by the discharge of contaminated dredged sediment into the containment site could exceed the New York State Department of Health (NYSDOH) recom mended maximum allowable 24-hour average ambient air PCB 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. MODIFICATIONS 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 arc 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 Che 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, end 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 project are not sufficient to be used for these purposes. These current funds are to be used only for dredging, site construction and closure, and a monitor ing program for only the duration of the project operations. Although there are substantial number of modifications and additions to the original and reducedscale projects, most are directed toward long-term elements subsequent to eon- S-10 HONS 009766 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 NCPA 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 Sagandaga 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-concaminated sediments to protect workers, residents, agricultural resources, and water supplies. Disposal 1. Modify disposal operations at Che 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 i ug/cu m ambient sir guideline is met, as well as the 0.2 ug/g (ppm) standard for crops set by the U.S. Food and Drug Administration. 3. Develop specific contingency plans for additional treatment of the supernatant from dewatering prior to discharge if permit limits (to be established) are exceeded. 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. S-il HONS 009767 2. Contingency plane for (a) long-term leachate collection and treatment, (b) landfill cap maintenance, (c) excessive PCB volatilization or methane generation, and (d) alternate water supply should monitoring indicate failure of containment site. 3. The 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 NYSDEC 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 storageof NYSDOT 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 disposal and long-term storage. 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 maintenance 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 fLovs. 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. CITIZEN INVOLVEMENT It is also recommended 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 S-L2 MGNS 009768 if so desired by the respective committees. the committees would 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 frae as this proposed project. 2. NYSDEC 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. S-13 HONS 009769 Chapter 1 2 TABLE OF CONTENTS Title EXECUTIVE SUMMARY ............................................................................. TABLE OF CONTENTS ........................................................................... LIST OF FIGURES ................................................................................ LIST OF TABLES AND PLATES.......................................................... INTRODUCTION ....................................................................................... History of the PCB Problem in the Hudson River... Purpose of and Need for the Project ................................ Drinking Water........................................................................... Food ................................................................................................. Air ................................................................................................... Heath Effects ........................................................................... Routine Maintenance Dredging ....................................... Hudson River Fishery .......................................................... Congressional Action .................................................................... Actions Proposed by the NYSDEC ............................................ Dredging ....................................................................................... Remnant Excavation ............................................................... Containment Site .................................................................... Mitigating Measures ............................................................. Rescoping of the Recommended Alternative ................... Action by EPA ..................................................................................... Permits ................................................................................................... State .............................................................................................. Federal .......................................................................................... PCB Standards and Recommendations ..................................... ALTERNATIVES CONSIDERED ............................................................. MAJOR ALTERNATIVES The No-Action Alternative ........................................................ No-Action (Assuming That Routine Channel Maintenance Dredging Will Continue)................... No-Action (Assuming That Routine Channel Maintenance Dredging Will Be Halted)................. Control of River Flows ............................................................... In-River Detoxification .......................................................... Degradation by Ultraviolet Ozonation ............... Chemical Treatment .......................................................... Bioharvesting ........... Activated Carbon Adsorption .................................... Page S-l i v vi l-l l-l 1-5 1-6 1-6 1-7 1-8 1-9 1-9 1-10 1-11 1-14 1-14 1-15 1-15 1-15 1-18 1-18 1-18 1-19 1-19 2-1 2-1 2-1 2-5 2-6 2-11 2-11 2-11 2-11 2-12 HONS 009770 Chapter 3 TABLE OF CONTENTS Title Dredging Alternatives - The Full-Scale Project.... Dredging Alternative - The Reduced-Scale Project.. Bank-To-Bank Dredging Project................................................. ALTERNATIVE COMPONENTS In-River Containment ................................................................... Remnant Deposit Alternatives ................................................ No-Action......................................................................................... Denial of Access........................................................................ In-Place Containment............................................................... Complete or Partial Removal.............................................. Transportation Alternatives.............................................. In-River Dredging Mechanisms................................................... Clamshell Dredging/Mechanical Unloading................. Clamshell Dredging/Hydraulic Pumpout Unloading. Hydraulic Dredging and Transport.................................. Other Dredging Systems.......................................................... Dredge Spoil Disposal................................................................... Detoxification............................................................................. Containment in Upland Disposal Site........................... SELECTION OF THE RECOMMENDED ACTION Recommended Action........................................................................... Findings................................................................................................... Modifications....................................................................................... Citizen Involvement........................................................................ AFFECTED ENVIRONMENT (EXISTING CONDITIONS)................. Earth Resources.................................. ............................................... Regional Geological Setting.............................................. Containment Site Geology..................................................... River Bed Materials in Upper Hudson River............ River Bed Materials in Lower Hudson River .......... Water Resources.................................................................................. Surface Water................................................................................ Groundwater..................................................................................... Water Supply.................................................................................. Aquatic Ecology.................................................................................. Flora................................................... ............................................... Wetlands and PCB Hot Spots................................................. Fauns................................................................................................... Hudson River Fishery............................................................... Terrestrial Ecosystem.................................................................... Flora................................................................................................... PCB Levels in Terrestrial Flora.................................... Fauna..................................................... Agriculture................................................................. .. Threatened or Endangered Species......................................... page 2-12 2-13 2-16 2-16 2-18 2-24 2-24 2-25 2-25 2-28 2-28 2-31 2-31 2-34 2-3S 2-37 2-38 2-40 2-44 2-46 2-47 2-49 3-1 3-1 3-1 3-4 3-8 3-12 3-12 3-12 3-14 3-16 3-17 3-18 3-19 3-23 3-24 3-32 3-32 3-33 3-37 3-37 3-38 ii HONS 009*71 Chapter 4 TABLE OF CONTENTS Title Environmentally Sensitive Area.............................................. Cultural Resources.................................................................... Scenic and Recreational Areas......................................... Floodplains and Wetlands...................................................... Air Resources....................................................................................... Climate............................................................................................... Air Quality..................................................................................... ENVIRONMENTAL CONSEQUENCES OF FEASIBLE ALTERNATIVES MAJOR ALTERNATIVES The No-Action Alternative.......................................................... No*Action (Assuming That Routine Channel Maintenance Dredging Will Continue)................... No-Action(Aesuiaing That Routine Channel Maintenance Dredging Will be Halted)................. Control of River Flows................................................................. In-River Detoxification............................................................... Full-Scale Project........................................................................... Reduced-Scale Project.................................................................... Bank-To-Bank Dredging.................................................................... ALTERNATIVE COMPONENTS In-River Containment...................................................................... Remnant Deposit Alternatives................................................... No-Action.......................................................................................... Denial of Access......................................................................... In-Place Containment............................................................... Complete and Partial Removal............................................ In-River Dredging Mechanisms................................................... Containment Site................................................................................ FEDERAL, STATEt LOCAL AND OTHER SOURCES FROM WHICH COMMENTS HAVE BEEN REQUESTED................................................... ABBREVIATIONS USED........................................................................... CORRESPONDING ENGLISH AND METRIC UNITS........................... REFERENCES.............................................................................................. LIST OF PREPARERS............................................................................. APPENDICES Appendix A - Health Exposure and Risk Assessment for Residents in the Vicinity of Operations Associated with the Dredging of the Upper Hudson River pag< 3-40 3-40 3-43 3-43 3-44 3-44 3-45 4-1 4-2 4-2 4-10 4-11 4-11 4-11 4-16 4-18 4-18 4-23 4-23 4-28 4-31 4-36 4-41 4-58 5-1 6-1 7-1 8-1 9-1 A-l iii HONS 009772 TABLE OF CONTENTS Chapter Title pg Appendix 8 - PCB Hot Spot Dredging Program Upper Hudson River, New York, Rescoping Report............................... Appendix C - Review of the Sediment Transport Model and Che PCB Ecosystem Model Appendix D - Cost Estimates for In-River Containment of Hot Spots and Covering of Rem nant Deposits......................................... Appendix E-Water Quality Data...................................... Appendix F-Hudson River Fish Fauna......................... Appendix G-Hudson river Fish PCB Analysis 1979 and 1980 Samples.................................. Appendix H-Air Quality Data.......................................... Appendix I-Recommended Guideline for PCB Levels in Air.......................................................... Appendix J-Estimate of Maximum Probable PCB Flux to the Atmosphere from the Hudson River Sediment Disposal Basin......... ............................................. g-1 C~l D-l E-l F-l C-l K-l 1-1 J-1 SUPPORTING DOCUMENTS (Available for inspection at designated depositories). Boyce Thompson Institute for Plant Research, Inc. 1977. An atlas of the biologic resources of the Hudson Estuary. Boyce Thompson Institute for Plant Research, Inc. Yonkers, New York. Malcolm Pirnie, Inc. 1980. PCB hot spot dredging program, upper Hudson River, New York. Draft environmental impact statement. Prepared for New York State Department of Environmental Conservation, Albany, New York. New York State Department of Environmental Conservation and United States Fish and Wildlife Service. 1978. Hudson River fish end wildlife repore. Hudson River level B study. 27 pp. + appendices. iv HONS 009773 Figure Number 1-1 2-1 2-2 2-3 2-4 3-1 3-2 4-1 Plate Number 1 2 3 4 LIST OF FIGURES AND PLATES Title Generalized Location River Flows and Concentrations In-River Containment Alternatives Dredge Illustrations Alternative Dredging Systems Rainfall - Intensity - Duration Frequency Curve for Albany, New York PCB Concentrations in Ambient Air at Washington County Offices Areas Used for Containment Site Modeling Title Location Map - 1 (River Mile 154 to 174) Location Map - 2 (River Mile 174 to 197) Original Containment Site Rescoped Containment Site Following Page 1-2 2-10 2-18 2-32 2-32 3-44 3-52 4-66 v MONS 009774 LIST OF TABLES Number 1-1 1-2 1-3 1-4 2-1 2-2 2-3 2-4 2-5 2-6 2-7 2-8a 2-8b 2-9a 2-9b 2-10 2-L1 2-12 3-1 3-2 . Title Major Event* in the Hudson River that Pertain to the PCB Problem Methods of Managing PCB-Contaminated Sediments in the Hudson River Estimated Program Costs PCB Standards and Recommendations Major Alternatives and Alternative Components PCB Transport: No-Action Alternative (with Navigational Dredging and Volatilization) PCB Transport: No Routine Maintenance Dredging (with volatilization) Comparison of Flow Contributions Average PCBs in the River Water Column Between Schuylerville and Stillwater PCB Transport: Full-Scale Alternative PCB Transport: Reduced-Scale Alternative Estimated Mass of PC8 in Remnant Deposits (metric measure) Estimated Mass of PCB in Remnant Deposits (English measure) page 1-3 1-12 1-16 1-20 2-2 2-4 2-7 2-9 2-10 2-14 2-15 2-20 2-21 Remnant Deposit Alternatives (metric measure) Remnant Deposit Alternatives (English measure) PCB Losses: Clamshell Dredging/Hydraulic Pumpout Unloading PCB Losses: Hydraulic Dreding and Transport EPA Recommended Program Characteristics of Soils Within the Containment Site Bed Deposit Properties 2-29 2-30 2-33 2-36 2-45 3-7 3-10 vi HONS 00977$ LIST OF TABLES Number 3-3 3-4 3-5 3-6 3-7 3-8 3-9 3-10 3-11 3-12 3- 13 4- 1 Tide Hoc Spots and Wetlands Means and Ranges of PCB Levels in Hudson River Fish PCB Trends for Striped Bass, Hudson River, 1973-80, Tappan Zee Bridge Increases in Foliage PCB Levels Foliage PCB Levels Near Fort Miller Dumpsite Summary of Cultural Resources Identified at Site 10 Total Suspended Particulates from High Volume Air Samples at Selected Stations, Upper Hudson River, 1979 Settleabie Particulates from 30-Day Dustfall Jars PCB Air Sampling by the New York State Department of Health Ambient PCB Levels at Site 10 and Lock 6 Dam Summary Tabulation of Air PCB Data by NYDEC Division of Air Resources Estimates of Total Daily PCB Ingestion Page 3-20 3-28 3-30 3-35 3-36 3-42 3-46 3-47 3-48 3-52 3-53 4-5 vii HONS 009776 CHAPTER 1 INTRODUCTION 1. HISTORY OF THE PCB PROBLEM IN THE HUDSON RIVER The Hudson River is one of Che nose heavily PCB-contaminated bodies of water in Che United States. The greatest mass of contaminated sediments are located in the upper Hudson River above Troy, New York. However, as a result of sediment migration, the effects of PCBs have now been identified farther down* stream. As a result, the affected area now encompasses the Hudson River region from Glens Falls to the New York Bight. A map indicating the geographic location of the project study area is presented in Figure 1-1. Polychlorinated biphenyls (PCBs) are a clasa of chemical compounds that have been used in agriculture and industry for decades. Since 1930, PCBs have been principally used in electrical transformers and capacitors but they also have been used in a variety of other products, including lubricants, pesticides, cutting oils, plasticizers, and adhesives. Melcolm Pirnie, Inc. (MPI, 1980d), reports chat during a 30-year period ending in 1977, over 22,700 kilograms (kg) (500,000 pounds (lb]) of PCBs were discharged to the upper Hudson River in the waste stream of two General Electric (GE) capacitor manufacturing plants at Fort Edward and Hudson Falls and from other relatively minor sources. Much of the contaminated material that had accumulated behind the former Fort Edvard Dam waa released downstream when the dam was removed in 1973 and during subsequent floods. Belatedly, PCBs were recognized as toxic, persistent pollutants. Though ubiquitous in their dis tribution, they were found in higher concentrations and mass in the Hudson River than were previously known to exist in any other North American body of water (MPI, 1980d). HONS 009777 1-1 Theoretically, there are 210 types (homologs) of PCBs. PCBs were avail* able commercially as mixtures (aroclors) of 20 to 75 horaolgs and marketed by the weight of chlorine contained in the mixtures. (MPI, 1980d). The compo sition of the PCBs discharged into the upper Hudson River by GE is reflected by purchase records of the two GE plants (Bopp and others, 1981). Between 1966 and 1970 more than 98 percent of their PCB purchases consisted of Aroclor 1242. In 1971, Aroclor 1242 was replaced with Aroclor 1016, a very similar aroclor. Between 1972 and 1976 more than 99 percent of Che purchases were Aroclor 1016. Cumulative purchases between 1966 and 1975 were 68 percent Aroclor 1242 and 31 percent Aroclor 1016 small quantities of Aroclor 1254 were used in the GE plants prior to 1966. A reasonable estimate for the entire period of plant operations is that 1242 comprised 80 percent of total purchases with the remainder principally 1016 and 1254 (Bopp and others, 1981). All three aroclors are now found in the sediments, water column, and biota of the Hudson River (MPI, 1980d). In a suit brought by New York State Department of Environmental Conser vation (NYSDEC) in 1976, GE was found to be largely responsible for the high concentrations of PCBs found in the Hudson River water, sediments, and organ* isms. As a result, GE was required to reduce its daily discharges of PCBs to 454 grama (g) (1 lb) and to build wastewater treatment facilities at their Hudson Falls and Fort Edward plants. By 1977, daily PCB discharges from Che GE plants had been reduced to less than 1 g (0.022 lb) (NYSDEC, 1977a). A brief outline of the history of the PCB problem is listed in Table 1-1. Much of the PCB-contaminaced material Chat washed downstream after the removal of the Fort Edward Dam concentrated in riverbed sediments from Fort Edward to the Federal Dam at Troy. In some casea, the concentration of PCBs in thssa sediments exceeds 50 micrograms per gram (ug/g) (50 parts per million (ppm)). These highly contaminated sites have been labeled hot spots. As a result of a survey completed during the summer of 1976, 40 hot spots have been identified in the upper Hudson River. An additional five areas of PCB deposition were exposed to the air when water levels dropped after the Fort Edward dam MONS 009773 1-2 HONS 009779 Table 1-1 Major Events in the Hudson River that Pertain to the PCB Problem Date 1822 1898 1950-1970 1950-1976 1973 (July-October) 1973-1974 (July-July) 1973 (Spring) 1974-1975 1974-1975 (October-July) 1976 (April 2) 1976 (September) 1976 1977 (July) 1977 (Sepcember-December) 1978 (April-June) Event Fort Edward 0am completed Fort Edvard Dam reconstructed Navigational dredging removes an average 17,600 cu o (23,000 cu yd) per year in Fort Edward area General Electric discharges some 22,700 kg (500,000 lb) PCBs to Hudson River from two capacitor plants in Hudson Falls and Fort Edward Fort Edvard Dam removed because its condition is deteriorating 650,000 cum (850,000 cu yd) are scoured from former dam pool and 604,000 cu m (790,000 cu yd) deposited in east and vest channels near Rogers Island 22,900 cu m (30,000 cu yd) dredged by contractor to Scott Paper Company 470,200 cu m (615,000 cu yd) dredged by NYSDOT from east and vest chsnnels near Rogers Island Timber rock cribs removed; rock placed to stabalize remnant deposits 3 and 4; banks shaped; dumped rock stabilizes remnant deposit 5 100-year flood occurs; additional 198,800 cu m (26,800 cu yd) scoured from unstabilized areas in former dam pool General Electric reduces daily PCB discharges to 454 g (11b) PCBs into Hudson River from the capacitor plants in Hudson Falls and Fort Edvard 26,800 cu m (35,OQO cu yd) dredged in the vicini ty of of buoy 212 by NYSDOT; fishery closed General ELectric reduces daily PCB discharges to less than 1 g (0.022 lb) PCBs into Hudson River from two capacitor plants in Hudson Falls and Fort Edward 37,600 cu m (180,000 cu yd) dredged from east channel and placed in new Moreau site 1-3 MONS 009780 Date 1978 (June-August) 1978 (October) Table 1-1 (continued) Event Banks of remnant deposits 3 and 5 restabilized 10,750 cu ra (14,000 cu yd) excavated from remnant deposit 3a and moved to Moreau sice Note: Place names referred to in this cable may be located on Plates 1 and 2 of this report. Source: MPI, 1980d 1-4 HONS 009781 was removed. A portion of one of these five remnant areas was removed by NYSDEC in October 1978, and deposited in the new Moreau landfill. At present five remnant areas remain in the Fort Edward area and may be contributing to PCB contamination of the Hudson River and the ambient air. The locations of the identified hot spots and remnant areas are shown on Plates 1 and 2. In addition to the hot spots and remnant areas, several landfills and New York State Department of Transportation (NYSDOT) dredge disposal sites in the area are known to contain PCBs and may contribute to PCS levels in (he Hudson River and the air. Ocher as yet unidentified sources of PCB contamination may also exist. 2. PURPOSE OF AND NEED FOR THE PROJECT PCBs have several characteristics that make them toxic to animals .includ ing human beings. They collect (bioaccuaulate) and concentrate (biomagnify) in the fatty cisaue of all organisms (e.g., the amount of PCBs in s fish can be many times greater then the amount in the surrounding water). Because they ere chemically stable compounds, they persist in the environment for many years. They have been shown experimentally to have e vide range of toxic effects. In addition to the health effects associated with PCBs, toxic impurit ies such as polychlorinated dibenzofurans (PCDFs) and chlorinated napthalenes are often closely associated with PCBs (MPI, 1980d). impurities amplifies the PCB problem (Appendix A). The presence of these The presence of PCBs, as well as heavy metals in the sediments of the upper Hudson River, poses e potential health risk to humans and other organisms from three principal sources: drinking contaminated water a eating contaminated food breaching contaminated air 1-5 HONS 009782 2a. Drinking Water Several communities obtain their drinking water from the Hudson River. Theae couaunitiea include the Village of Waterford, Port Even Water District, the Village of Rhinebeck, the City of Poughkeepsie, and the Highland Water District. In addition, several municipalities, such as Stillwater and Green Island, draw water from infiltration galleries located along the upper Hudson River. Many households draw water from wells located close to the Hudson River. The U.S. Geological Survey (USGS) maintains five gaging stations in the upper Hudson River at Glens Falls, Rogers Island, Schuylerville, Stillwater, and Waterford (MPI, 1980d). At the Glens Falls gaging station, located above the GE plants, concentrations of PCBs are usually below the detectable level of 0.1 micrograsis per liter (ug/1) (0.1 parts per billion [ppb]) (Tofflemire, NYSDCC, 1980). From 1976 to 1979 the average concentrations at Schuylerville and Still' water ranged from 0.S68 ug/1 (ppb) to 0.687 ug/1 (ppb) (Tofflemire, 1980). However, where suitable treatment facilities are available, PCBs can be removed from river water, leaving it suitable for drinking. As shown by tests conducted in 1972 by the City of Poughkeepsie, PCB levels in Hudson River water can be reduced by 40 to 80 percent through activated carbon filtration (Cranston, 1977). This removal rate resulted in PCB concentrations in the treated water below the maximum level of 1.0 ug/1 (ppb) presently recommended by the New York State Department of Health (NYSDOH). At present there are no PCB standards in either the federal or state drinking water regulations. 2b. Food As mentioned previously, a characteristic of PCBs that makes them dangerous to humans and ocher animals is ehat they collect and concentrate in the fatty tissues and the fatty portions of blood and milk. This characteristic causes PCBs to appear in relatively high concentrations in meat, fish, and poultry products. Comprehensive human food monitoring data on PCB levels are not available for the Hudson River area. However, the U.S. Food and Drug Administration (FDA) 1-6 MGNS 009783 conduces sn annual comprehensive food surveillance program to determine the concentrations of pesticide residues, PCBs, heavy metals, and ocher contaminants in the diets of U.S. consumers. Data for the period from 1969 co 1977 indicate chat during this period Che total daily intake of PCBs per person dropped from 15.0 to 8.7 micrograms per day (ug/d). However, intake of PCBs from the meatfiah-poultry categorize changed little (9.5 to 8.1 ug/d). The decrease of PCBs in total diet is attributable to decreasing levels of PCBs in food packaging material after 1974 (USEPA, 1976b). The present FDA standards for PCB in food are: Milk fat and dairy products Poultry Eggs Fish and shellfish Finished animal feed (including hay) 1 .5 "*/g 3.0 ug/g 0.3 Ug/g 5.0 ug/g 0.2 ug/g (ppm) (ppm) (ppm) ( ppm) (ppm) Since the FDA data indicate that the meat-fish-poultry category is primarily responaible for dietary intake of PCBa, the possible local exposure eo PCBs resulting from the opening of the fishery in che upper Hudson River must be considered. The FDA data on PCB concentrations in fish ranged from trace levels to 0.05 ug/1 (ppm); the data on PCB levels in fish from the the upper Hudson River indicate levels ranging up to 500 ug/1 (ppm) (Thomann and St. John, 1979). Some illegal commercial fishing and some subsistence fishing are believed to take place in the upper Hudson River despite che NYSDEC ban. Populations along the Hudson River that do not consume fish taken directly from the river are expected to be exposed to at least 9 ug/d of PCBs through injastion of food. This figure represents the national background level es timated by EFA. Consumption of Hudson River fish with PCB levels at the 5 ug/g (ppm) FDA standard could increaae this amount by 100 times to approximately 900 ug/d (Appendix A). 2c. Air PCBs volatilize, or escape into the air, from a variety of sources includ ing plastics, gas lines, and oils. For example, the average PCB concentration in a kitchen has been reported at 0.32 micrograms per cubic meter (ug/cu m) (USEPA, 1976b). The populace in Fort Edward and Hudson Falls is exposed to a 1-7 HONS 009784 general background concentration of 0.05 to 0.10 ug/cu a (Kerr, NYSDEC, May 8, I960), and the rural populace ia exposed to concentrations of less than 0.01 ug/cu a (Buckley, Boyce Thompson Institute for Plant Research, Inc. [BTI], April 9, 1981). These exposure levels are due to PCB volatilization fron the river, remnant deposits and disposal sites. Residents of the upper Hudson River are therefore exposed to between 0.7 to 4.6 ug/d of PCBs, depending on the amount of time an individual spends indoors (Appendix A). Residents adjacent to existing dumpsites containing PCBs could be exposed to greater levels. In 1977, the National Institute of Occupational Safety and Health (NI0SH) proposed an 8-hour (hr) maximum allowable PCB exposure in air of 1 ug/cu m. The existing Occupational Safety and Health Administration (OSHA) standard for 8-hour maximum allowable PCB exposure in air is 500 ug/cu m. However, these standards refer to industrial situations and are therefore not directly applicable to outdoor ambient air conditions. In a letter dated March 25, 1981, NYSDOH recom mended that "...the 24 hour average PCB concentrations in the ambient air at occupied residences and other sensitive receptors...do not exceed l ug/cu mM (Appendix I ). 2d. Health Effects PCBs have been associated with a variety of adverse health effects (World Health Organization (WHO], 1976). Studies performed with rats, mice, and monkeys revealed that various types of toxicity are associated with PCBs, including liver damage, reproduction effects, skin disturbances, and cancer. Although moet of these data are available for species ocher than humans, humans appear to be the species most sensitive to PCBs (WHO, 1976). Considerable study has been given to an incident chat occurred in 1968 in Japan. Rice oil contaminated with PCBs wes consumed by the general populace (WHO, 1976). Health effects included chloracne, increased pigmentation of the skin, increased eye discharge, visual disturbances, weakness, numbness, headachas, and liver dysfunction. Babies born to exposed mothers during this time were smaller than average and had skin discoloration. By May of 1975 a total of 1-8 MONS 009785 1,291 reLated disease cases were reported. However, it was discovered than an extremely toxic impurity, PCDF, was present in the contaminated oil and that this may have been responsible for some or all of the toxic effects. Rhesus monkeys exposed to pure PCBs at levels similar to those in the rice oil, however, de veloped similar symptoms (Alien and others, 1974). Health effects specific to PCB exposure have been documented for industrial workers involved in the direct manufacture or use of PCBs. These effects include chloracne, fatigue, headaches, numbness of limbs, and swelling of joints (Matthews and others, 1979). However, PCB effects on the general population from environmental exposure have not been well documented (MPI, 1980d). Health effects of exposure to PCBs are discussed in more detail in Appendix A. 2e. Routine Maintenance Dredging The regulations pursuant to the Toxic Substances Control Act (TSCA) of 1976 require that special precautions for upland disposal be provided for those substances, such as sediments and liquids, contaminated by greater than 50 ug/g (ppm) of PCBs. Based on required procedures for determining the disposal options for the dredge spoils obtained through normal channel maintenance operations in the lower Hudson River, the presence of concentrations of PCBs greater than 4 ug/g (ppm) could make ocean disposal infeasible in the future (Curil, Save Our Ports, March 24, 1981). Therefore, the PCB-contaminated sediments in the Hudson River, as discussed above, have the potential for imposing severe economic hardships on upper and lower Hudson River communities that depend on dredging to keep ports operating and channels navigable. 2f. Hudson River Fishery The Hudson River fishery resource is of considerable local and regional importance. It serves as a commercial and recreational fishery as well as a major spawning area for fishes of the eastern Atlantic. Sheppard (1976) esti mated that the Hudson River could potentially produce an annual cosmiercial finfish catch of 600,000 to 900,000 kg (1,240,000 to 1,960,000 lb), worth $261,000 to $426,500 (in 1976 dollars). 1-9 MOMS 009786 The recreational fishery in the upper Hudson River is presently elosed because of PCS contamination. In 1976, Sheppard estimated that the upper Hudson River could potentially support 100,000 man-days of fishing (angler days), which, at an average angler expenditure of $12.50 per day, would be worth $1,250,000 annually (in 1976 dollars). The recreational value of the lower Hudson River fishery is currently on the order of $1,350,000 annually. Sheppard (1976) estimates that the lower Hudson River may potentially provide over of e million angler days of recreational fishing annually, worth over $12,500,000 (in 1976 dollars). 3. CONGRESSIONAL ACTION In September 1980, Congress recognized the existing PCB problem in the Hudson River by passing an amendment to the Clean Water Act (CWA) under Title I, Section 116(a) and (b), entitled the "Hudson River PCB Reclamation Demonstration Project". Funds for this project have been appropriated under Title II, Section 205(a) of Che CWA. Under this legislation, the United States Environmental Protection Agency (EPA) is authorized to expend up to $20,000,000 toward a proposed demonstration reclamation project to remove and dispose of PCB-contemineted sediments from the Hudson River. The amendment reads as follows: Sec. 116. (e) 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 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 systems for such landfills. Such demonstration project shall be for Che purpose of determining the feasibility of indefinite storage in secure landfills of toxic substances and of ascertaining the im provement of the rate of recovery of a toxic contaminated national waterway. No pollutants removed pursuant to this paragraph shall be placed in any landfill unless the Administrator first determines that disposal of ths 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 made on condition that non-Federal sources provide the remainder of the cost of such project. The authority of this 1-10 MGNS 009767 section shall be available until September 30, 1983. Funds allotted to the State of Hew 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 clean up fund. Any funds used under the authority of this subsection shall be deducted from any estimate of tha needs of the State of New York prepared under Section 516(b) of this Act. The Administrator may not obligate or expend more chan $20,000,000 to carry out this Section. 4. ACTIONS PROPOSED BY THE NYSDEC* As a result of enforcement action taken by the NYSDEC against GE and a subsequent settlement, NYSDEC spent approximately $3,000,000 to investigate the PCS contamination problem in the Hudson River. These studies described the extent of PC8 contamination and proposed methods to reduce and remove the threat of continued PCS contamination of the Hudson River. The culmination of this effort was the issuance of a draft State Environmental Quality Review Act (SEQRA) Environmental Impact Statement (EIS) prepared by MPI (1980d). The alternative originally recommended by NYSDEC in the draft SEQRA EIS (MPI, 1980d) included the following components: dredging of 40 hot spot areas in the river bed with containment in a secure upland site design and construction of a secure upland containment site capable of long-tarm isolation of contaminated material a excavation of remnant deposits 3 and 5, located above the former Fort Edvard Dam site, and removal to the upland containment site a provision for containment of material from three PC5-contaminated dumpsites in the Fort Edvard jrea should removal be found more suitable than in-place containment a provision for containment of contaminated material from three NYSDOT dredge spoil sites a destruction of the recovered PCBa at such time as a technically and economically feasible procedure becomes available In arriving at their recommended alternative, NYSDEC and its consultant, MPI, first examined the feasibility of several alternative methods of managing I-IL HONS 009788 Alternatives Table 1-2 Methods of Managing PCB-Contaminated Sediments in the Hudson River Status of Technologic Development Potential Constraints or Environmental Problems In-Situ Control Depredation by ultreviolet ozonation - . Chemical treatment Erosion control of river bottom Covering PCB-contam inated sediments Developed for closed system applications Conceptual Conceptual Conceptual Treataent requires closed reaction vessel Possible ecological side effect* Interference with navigation Massive disturbance of ecosystem. Rupture of seal or ballooning of plastic due to gas for mation. Placement and stabilization of cover difficult Removal Bioharvesting Activated carbon adsorption Dredging Conceptual Laboratory Demonstrated on small scale. Fort Edward Channel The time and costs involved with harvesting enough fish are prohibitive. Tremendous ecological side effects Technology for application and retrieval has not bean proposed Untested on a large scale 1-12 HONS 009789 Table 1-2 (Continued) Methods of Managing PCB-Concamioated Sediments in the Hudson River Alternatives Status of Technologic Development Potantial Constraints or Environmental Problems On Land Control Containment in disposal site Incineration Chemical detoxification Biodegradation Demonstrated at new Moreau site Demonstrated on small scale Laboratory Laboratory Lont-term monitoring and maintenance Large scale incinerator, extensive use of fuel, wet sediments Best results with high PCB concentrations Aerobic reaction only, with potential undesir able byproducts Source: MPX, 1980d 1-13 HONS 009790 PCB-contaminated sediments in the Hudson River, including the ultimately recom mended dredge and encapsulation alternative. These alternatives are sumsMrised in Table 1-2. Most of them, however, are somewhat conceptual in nature and therefore would require several years of research and field demonstration before they could be implemented. Hence, they failed to satisfy the dominant criterion Chat led to the selection of the more feasible solution of hot spot dredging, transport, and encapsulation: the need to remove PCBs as quickly as possible from the river bottom in order to avoid downstream dispersal during flood flows. Once NYSDEC concluded that dredging presented the most feasible means of hot spot management, alternative dredging programs, various types of dredge equip ment, alternative remnant deposit excavation programs, candidate containment sites, and various mitigation measures for maximizing long-term isolation of PCB-contaminated material at the containment sice were evaluated. The draft SEQRA EIS and its supporting documents indicate that these components of the recommended alternative would result in the containment of 40 to 50 percent of the PCB estimated to be in the upper Hudson River. The following sections briefly describe each of the components of the alternative recommended by the NYSDEC. 4a. Dredging The dredging operation would be preceded by an extensive sampling program to specify further the exact locations and concentrations of PCB hot spots. A combination of clamshell and hydraulic dredging, depending on distance from the containment site, would then be used to remove the 40 hot spots from the river bottom (Pletea 1 and 2). Modifications to che equipment would be made to limit the escape of contaminated dredge spoils beck into the river. Again, dapending on the distance, the dredge spoil would either be pumped out hydraulic ally or be transported by barge to the containment site. 4b. Remnant Excavation Two of the remnant deposits that have accumulated behind the former Fort Edvard Dam would be excavated end their material transported to the containment site. It was dtcided to excavate portions of remnant areas 3 and 5, which 1-14 HONS 009791 contain the highest PCB levels, after evaluating various partial removal, in-place encapsulation, and no-act ion alternatives for the remnant sites. 4c. Containment Site A 100-hectare (ha) (250-acre [aJ) containment site (Site 10), located 4 kilometers (km) (2.5 miles (mi]) south of the Village of Fort Edward, was selected on the basis of size, clayey subsoil, accessibility, and environmental and socioeconomic factors (Plate 3). A single site, rather than multiple sites, was identified in order to realize economies of scale, to limit contaminated material to a single location, and to reduce the amount of land needed for buffer areas. The proposed site, which in addition to the containment area includes a roughing and storage pond, surge pond, pump station, treatment plant, and le achate collection and stormwater drainage systems, would be fenced to restrict public access, and a clay cover would be installed over the containment area to reduce infiltration, erosion, and volatilization. The proposed cover consists of s 46-cencimeter (cm) (18-inch (in]) thick layer of clay overlain by gravel, topsoil, and s shallow-rooted vegetative groundcover. 4d. Mitigating Measures Various measures aimed at mitigating adverse environmental impacts at each step of NYSDEC's recommended alternative are described in Chapter 9 of the draft SEQRA EIS (MPI, 1980d). Of particular interest are the long-term maintenance and moitoring activities proposed for the containment site and ita environs. Maintenance would include leachate collection, cap repairs, reseeding, mowing, application of lime, and repair of drainage ditches. Monitoring includes groundwater sampling, inspection of cap and cover crop, and sampling of cover crop and adjacent vegetation for PCB contamination. 5. RESCOPINC OF THE RECOMMENDED ALTERNATIVE Cost estimates for the alternative originally recommended by NYSQEC cal culated for base year 1979 and escalated for inflation over a 3-year imple mentation period, are shown in Table i-3. The estimated total cost of the 1-15 HONS 009792 Table 1-3 Estimated Program Costs (Thousand Dollars) Phase Site Construction Thompson Island Pool Dredging Remnant Pool Deposits Removal Lock 5 - Lock 6 Hat Spots Dredging Locks 2, 3 & 4 Hot Spots Dredging Sub-Total Base Tear 1979 1980 $2259^ $2711*2) 4847 6011<3) $2982 1698 2106*3* 2982 3698*3) 3359 4165(3) $2982 Contingencies Engineering Design Field Engineering & Construction Administration Legal & Administrative Totals By Tear Total For Project Scientific, Engineering, Honitoring 4 Administrative Costs 9/76-3/80 Scientific, Monitoring & Administrative Estimated 4/80-3/83 796 278 384 69 $4509 II A 1982( $7272 2548 $9820 2664 930 1062 2S7 $14733 $34,720 . 3.480 1.600 $40,000 1W<4 $4922 5040 $9942 2712 1018 1493 293 $15478 Notes: 1. 2. 3. 4. Includes site vork costs for all phases Escalated 20 percent Escalated 24 percent Escalated 10 percent/year Source: MPI, 1980d 1-16 HONS 009793 project is $40,000,000. This amount is twice the level of federal funding authorised by Congress in October 1980, under amendments to the CWA for the Hudson River Reclamation Demonstration Project. As a result, the recommended project was rescoped (scaled down) by NYSDEC to bring it within the total funding available at the present time -- $20,000,000 of federal monies and $6,700,000 of New York State monies. The following criteria were used for the rescoping: maximization of PCB removal from the Hudson River e program performance e cost-effectiveness avoidance of wetlands flexibility Using these criteria, the NYSDEC proposed the following modifications to the original project: deletion of remnant deposit relocation and containment provision of top dressing and fencing for remnant areas 3 and 3. deletion of provision for NYSDOT spoil areas containment elimination of provision for the containment of PCB-eontaminated dumps reduction of the number of hot spots to be dredged reduction of capacity at the containment site reduction in the scope of research studies Reduction in the capacity of the containment site would result from reduc tions in the volume of material to be encapsulated, as well as a refined defini tion of materials handling requirements at the site. The reduced dredging program is justified by NYSDEC on the basis that lower pool hot spots are more expensive to recover, while containing lese than one quarter of the PCBs (end at a generally lower concentration) than PCBs found in the Thompson Island Pool. Furthermore, lower pool hot spots, some of which are associated with wetlands, are further from the proposed containment site and therefore more costly to transport and encapsulate upland. 1-17 HONS 009794 6. ACTION BY EPA With the passage of the Section 10 amendments to the CWA in October 1980, Congress authorized EPA to make grants to the NYSDEC to carry out the intent of the Hudson River PCS Reclamation Demonstration Project. The intent of the legislation is discussed above (Section 3). On January 12, 1981, EPA Region II issued a Notice of Intent (NOI) to prepare an EIS in accordance with the National Environmental Policy Act (NEPA). The purpose of NEPA is to identify and analyze significant impacts on the quality of the human environment that may result from the federal funding of a proposed action*, in this case, the proposed dredging, disposal, and storage activities associated with the Hudson River PCB problem. In addition, the NEPA EIS decision-making process provided the forum for soliciting public comment on the proposed project by conducting a series of public meetings and hearings and by the formation of a Citizens Advisory Com mittee (CAC). 7. PERMITS State and Federal permits which would be required for the dredge, fill, and discharge operationa are enumerated below. Additional information regarding State and Federal permits is presented in Appendix B of the SEQRA EIS (MPl, 1980d). 7a. State 360 Permit A complete application for e construction permit pursuant to the New York State Solid Waatc Management Facilities Rules must be submitted to NYSDEC for the purpose of constructing a solid waste management facility. Article 24 In accordance with recommendations of W.A. Huermann, Region 5W, Bureau of Regulatory Affairs, a Freshwater Wetlands Permit will be required to construct Site 10 and to dredge the river near hotspot No. 18 and hoc spot No. 39. 364 Permit If trucking is required for the removal and transport of contaminated material from the remmnant deposits, the contractor must secure a permit pursuant to the rules governing Collection and Transport of Industrial - Commercial and Certain Other Wastes. 1-18 MQNS 009195 State Pollution Discharge Elimination System A SPDES permit will be required for Che discharge from the containment site. Streambed Disturbance Permit This permit will not be required since the state is the applicant for this project. New York State Siting Board A certificate of Environmental Safety and Public Necessity must be issued by the Hazardous Waste Facilities Siting Board. 7b, Federal Toxic Substance Control Act A PCB disposal approval must be issued for this project by the EPA Regional Adminstrator. The Clean Water Act: Section 404 This permit will be required by the U.S. Army Corps of Engineers (USACOE) if the discharge from the containment area is into navigable waters or adjacent wetlands of the United States. River and Harbor Act1. Section LQ This permit will be required by the USACOE for dredging in navigable waters. 8. PCB STANDARDS AND RECOMMENDATIONS The PCB standards and recommendations promulgated by state and federal agencies are summarized In Table 1-4. 1-19 HONS 009796 Table 1-4 PCB STANDARDS AND RECOMMENDATIONS Source of Intake Food (FDA standards) Milk fat and dairy products Poultry Eg * Fish and shellfish Finished animal feed (including hay) Drinking Water (NYSDOH recommendation) Ambient Air Occupied residences and other sensitive receptors (NYSDOH recommendation) Worksite (OSHA standard) Workside (NIOSH recommendation) Maximum Allowable PCBs 1.5 ug/g (ppm) 3.0 ug/g (ppm) 0.3 ug/g (ppm) 5.0 ug/g (pp*)1 2 3 0.2 ug/g (ppa) 1.0 ug/1 (ppb) 2 1.0 ug/cu m 500 ug/cu m ^ 1.0 ug/cu m Note: 1. Proposed FDA revision to 2.0 ug/g (pptn) 2. 24-hour average; applicable to Hudson River reclamation project only (Appendix I) 3. 24-hour average; if exceeded, respirators are required 1-20 MONS 009797 CHAPTER 2 ALTERNATIVES CONSIDERED This chapter presents further evaluation and discussion of the alterna tives that NYSDEC offered in its draft SEQRA EIS, as well as additional alterna tives investigated by EPA in addressing the PCB problem in the Hudson River. In some cases, a major alternative is comprised of a number of components. Table 2-1 lists the major alternatives and components being examined. Each major alternative and its respective components are discussed in the following sections. I. MAJOR ALTERNATIVES 1. THE NO-ACTION ALTERNATIVE This EIS is being prepared in accordance with NEPA. Of great importance in the NEPA EIS process is the evaluation of the no-action alternative. The no-action alternative is typically an alternative not to fund any proposal (aa for example, the PCB dredging project proposed by NYSDEC) and includes a consideration of what may happen in the project area if no action is taken. The impacts of the no-action alternative in this case depend on two options: the continuation of routine channel maintenance dredging or the cessation of it. The effects of these options on the no-action alternative are discussed below. lA. No-Action Alternative (Assuming That Routine Channel Maintenance Dredging will Continue) The no-action alternative includes no work beyond routine channel main tenance dredging. If routine channel maintenance dredging continued over the next 10 years, it would remove an estimated 2,300 kg per year (3,000 lb/yr) of PCBs, or an estimated 15 percent of the PCBs present in the upper Hudson River bed (Hetling and others, 1978). Bssed on UAPORA's evaluation of the upper Hudson River PCB No-Action Alternative Study (Lawler, Matuakey, and Skelly [LMS], 1978) presented in Ap pendix C, the results of the LMS model can be considered as the best available estimates of average annual PCB loadings from the upper Hudson River to the 2-1 HONS 009798 Table 2-1 Major Alternatives and Alternative Components I. MAJOR ALTERNATIVES 1. THE NO-ACTION ALTERNATIVE IA. Assuming chat routine channel maintenance dredging will continue IB. Assuming that routine channel maintenance dredging will be halted 2. CONTROL OF RIVER FLOWS 3. IN-RIVER DETOXIFICATION 3A. Degradation by ultraviolet ozonation 3B. Chemical treatment 3C. Bioharvesting 3D. Activated carbon adsorption 4. DREDGING ALTERNATIVES--THE FULL-SCALE PROJECT 5. DREDGING ALTERNATIVES--THE REDUCED-SCALE PROJECT 6. BANK-TO-BANK DREDGING PROJECT II. ALTERNATIVE COMPONENTS 1. IN-RIVER CONTAINMENT (as an alternative to dredging)) 2. REMNANT DEPOSIT ALTERNATIVES 2A. No-action 2B. Denial of access 2C. In-place containment 2D. Complete or partial removal 2E. Transportation alternatives 3. IN-RIVER DREDGING MECHANISMS 3A. Clamshell dredging/mechanical unloading 3B. Clamshell dredging/hydraulic pumpout unloading 3C. Hydraulic dredging and transport 3D. Other dredging systems 4. DREDGE SPOIL DISPOSAL 4A. Detoxification . physical destruction through incineration e chemical treatment e biodegradation 4B. Containment in upland disposal sites dewatering by gravity dewatering by mechanical methods III. SELECTION OF THE RECOMMENDED ACTION 1. RECOMMENDED ACTION 2. FINDINGS 3. MODIFICATIONS 4. CITIZEN INVOLVEMENT HGNS 009799 2-2 estuary at Troy. It is importanc to note that, while the LMS model adequately reflects the effects of short duration high flows on increasing PCB transport, it does not take into account volatilization of PCBs nor routine maintenance dredg ing. PCBa are currently volatilizing from the upper Hudson River water at an estimated rate of 1,350 kg/yr (3,000 lb/yr) (Shen and Tofflemire, 1979J. Adjust ing the LMS model for a 35-yr average annual volatilization rate of 680 kg/yr (1,500 lb/yr) of PCBs from the upper Hudson River and assuming a 35-yr average routine dredging removal rate of 1,100 kg/yr (2,500 lb/yr) of PCBs from the upper Hudson River, the no-action alternative would result in the transport of 82,BOO kg (182,000 Lb) of PCBs into the estuary over the next 33 years, where they would be essentially unrecoverable (Table 2-2). During this period, 37,500 kg (82,500 lb) of PCBs would have been removed from the upper Hudson River by routine channel maintenance dredging, and 22,500 kg (49,500 lb) of PCBs would have been volatilized. The estuarine portion of the river below the Federal Dam is estimated to contain 75,700 kg (167,000 lb) of PCBs (Bopp, 1979; Bopp and others, 1981). New York Harbor is considered to have the greatest mass of PCBs below the dam, totaling 23,100 kg (51,000 lb) at an average concentration of 3 ug/g (ppm) (MP1, 1980d). This mass of PCBs in New York Harbor is 31 percent of the PCB load below the Federal Dam. Bopp (1979) estimates that over the past 20 yesrs, 1,800 kg/yr (4,000 lb/yr) of PCBs have been dredged from the harbor and that 70 to 75 percent of the harbor's PCBs originated from discharges to the upper Hudson River. Applying the results indicated in Table 2-2 and assuming that 1,800 kg/yr (4,000 lb/yr) of PCBs are dredged from New York Harbor and that a maximum of 31 percent of the PCB load at Troy enters New York Harbor, the average PCB concentration in the harbor sediments would decline by approximately 2 ug/g by the year 2000. (If it were assumed thet 100 percent of the PCB load at Troy enters New York Harbor, the average PCB concentration in the harbor sediments would double to approxi mately 6.0 ug/g (ppm) by the year 2013. ) The average PCB concentration in Albany eurning basin sediments is higher than in New York Harbor sediments. Much of the PCB load at Troy settles in the turning basin, causing the PCB concentrations to continue to increase until the year 2013. The bioassay matrix presently used by 2-3 MONS 009600 Table 2-2 PCB Transport: No-Action Alternative ^ (with Navigational Dredging and Volatilization)1 Period Average Annual CB Load at Troy kg/yr (lb/yr) Condition 1977 to 1978 1979 to 1994 1995 to 2013 After 2013 3,600 (8,000) 3,270 (7,200)3 1,950 (4,300) 0 (0) Before remnant deposit actions 16 years to exhaust supply above Lock 7 19 years to exhaust supply between Lock 7 and Troy Supply exhausted above Troy 1981 to 2013: 82,800 kg (182,000 lb) of PCBs transported into estuary. Notaa: 1. Aasumea volatilization rate of 680 kg/yr (1,500 Ib/yr) of PCBs from upper Hudson River. This rate is the average volatilization between 1981 and whatever year no PCBs remain in the upper Hudson River, or 1/2 the current volatilization race. Assumes routine navigational channel maintenance dredging of 1,100 kg/yr (2,500 lb/yr) of PCBs. This removal race is the average rate between 1981 and whatever year no PCBs remain in the upper Hudson River, or 1/2 the current removal rate. 2. Loadings do not reflect yearly fluctuations of river discharges and variations of the PCB mass transported. 3. Assumes contribution from retfinant deposits is negligible. 2-4 HONS 009Q01 EPA and Che USACOE for determining the viability of ocean disposal of PCB-con taminated sediments suggests chat 4 ug/g (ppm) may be the highest acceptable PCB level for ocean disposal (Curll, Save Our Ports, March 24, 1981). PCB hot pots also contain high levels of certain heavy metals which would further interfere with ocean disposal of dredge spoils. Moat PCB transport occurs during short duration high flows, not averaga flows. (For quantitative analysis of high flows, see section 2 of this chapter.) During very high upper Hudson River flows, substantial loadings of PCB will move rapidly downstream. Although the LMS model (and the refinements of it presented in Table 2-2) considers short duration high flows, it does not consider the effects of uneven downstream deposition of PCB sediments. Deposition near a potable water intake could threaten that supply. Deposition on a spawning ground could threaten a species. Deposition in a navigational channel or docking area could prevent disposal of dredge spoils in the ocean and require additional upland containment sites for upper and Lover Hudson River maintenance dredging activities. A problem that exists under any alternative until the fishery is reopened is Che health risk posed by illegal commercial fishing and subsistence fishing. The no-action alternative would leave ell the PCB sediments in the river, from which fish will accumulate PCBs. When the commercial fishery is legally reopened, PCDFs in cooked fish may continue to pose a substantial health risk. PCDFs, which may be more concentrated in cooked fish than in raw fish, are 200 to 500 times more toxic than PCBs (FDA, 1979). The no-action alternative described above does not require a containment site. However, this does not preclude the possible need for containment sites in the future to dispose of PCB contaminated sediments from maintenance dredging operations if dredging were to continue. IB. No-Action Alternative (Assuming That Routine Channel Maintenance Dredging Will be Halted) this alternative corresponds to the no-action alternative presented in 2-5 HONS 009802 the draft SEQRA EIS (MPI, 1980d) and in the Upper Hudson River PCB No-Action Alternative Study (LMS, 1978). It assumes chat routine channel maintenance dredging in the upper Hudson River will be halted. Adjusting the LMS model presented in the draft SEQRA EIS for a 50-yr average annual volatilization rate of 680 kg/yr (1,500 lb/yr) of PCBs from the upper Hudson River, the no-action alternative would result in the transport of 112,000 kg (247,000 lb) of PCBs into the estuary over the next 48 years, where they would be essentially unrecoverable (Table 2-3). During this period, 325,600 kg (72,000 lb) of PCBs would be volatilized from the upper Hudson River. the average PCB concentration in New York Harbor sediments would not increase, but the levels in Albany turning basin sediments would continue to increase until the year 2028. This analysis indicates that if dredging were halted, 36 percent more PCBs would be transported into the eatuary than if dredging continued. In addition, if dredging were halted, PCB transport would continue until the year 2028 rather than Che year 2013. This alternative will have greater negative impacts Chan the preceding no-action alternative. In addition to the adverse impacts resulting from PCB-concaminated sediments remaining in the river, substantial adverse impacts on the regional economy will result if routine maintenance dredging is halted. 2. CONTROL OF RIVER FLOWS Evaluation of the no-action alternative indicated that resuspension of PCB-contaminated sediments and migration of PCB hoc spots occur repeatedly during high river flows and that such movements of PCBs pose long-term risks to (l) potable water supplies downstream, (2) Che commercial fishery, (3) aquatic and wetland biota, (4) the population of shortnose sturgeon, an endangered species, and (5) future disposal of channel maintenance dredge spoils from the estuary. This conclusion suggested an alternative chat had not been considered in the drsfc SEQRA EIS (MPI, 1980d) or in Che rescoping report (Appendix B): control of high river flows. The new alternative entails controlling upper Hudson River flows from one source, the Great Sagandaga Lake at the Conklingviile 2-6 HONS QQ9803 Table 2-3 PCB Transport: Wo Routine Maintenance Dredging (with Volatilization) Period 1977 to 1978 1979 to 1994 1995 to 2028 After 2028 Average Annual C8 Load at Troy kg/yr (lb/yr) 3,600 (8,000) 3 3,270 (7,200) 1,950 (4,300) 0 (0) Condition Before remnant deposit actions 16 years to exhaust supply above Lock 7 34 additional years to exhaust supply between Lock 7 and Troy Supply exhausted above Troy 1981 to 2028: 112,000 kg (247,000 lb) of PCB transported into estuary. Notea: 1. Assumes volatilization rate of 680 kg/yr (1,500 lb/yr) of PCBs from Upper Hudson River. This rate is the average volatilization between 1981 and whatever year no PCBs remain in the upper Hudson River, or 1/2 the current volatilization rate. ' 2. Loadings do not reflect yearly fluctuations of river discharges and variations of the PCB mass transported. 3. Assumes contribution from remnant deposits is negligible. 2-7 HONS 009604 Dam, where substantial flow enters the upper Hudson River. However, the major water source of the Hudson River enters from Lake Luzerne at Hadley. Additional inflows from runoff, creeks, and groundwater enter the river beeween the Sagandaga-Hudaon confluence and Fort Edward. Table 2-4 compares the flow contributions from these sources during average flows and during the 100-year flood that occurred on April 2, 1976. Since 1977, the USGS has operated PCB monitoring stations at Glens Falls, Rogers Island, Schuylerville, Stillwater, and Waterford. Data from these moni tors indicate that PCB concentrations in the waters of the upper Hudson River are flow-dependent. As shown in Figure 2-1, relatively high PCB concentrations occur at low flows of less Chen 200 cubic meters per second (cu m/s) (7,000 cubic feet per second [cfs]) between Schuylerville and Stillwater. The concentrations are reduced in the moderate flow range and then increase again in the high flow range, greater chan 340 cu m/s (12,000 cfs) (MP1, 1980d). The average flow between Schuylerville and Stillwater is 140 cu m/s (5,000 cfs); 10 percent of the time the flow exceeds 340 cu m/s (12,000 cfs); and 1 percent of the time the flow exceeds 765 cu m/s (27,000 cfs). However, if the data from Figure 2-1 are converted to load of PCBs in Che river water column, rather than concentration, it becomes apparent that all flows less chan 340 cu to/s (12,000 cfs) beeween Schuylerville and Stillwater carry very low loads of PCBs (Table 2-5). Therefore in order to avoid substantial resuspension and migration of PCBs it would be necessary to prevent flows from exceeding approximately 340 cu m/s (12,000 cfs) over the hot spots. Based on Che above analysis, it appears chat the regulation of water flow over the Conklingville 0am could not substantially contribute to achieving this goal becauaa flows greater than 340 cu m/s (12,000 cfs) occur 10 percent of the time between Schuylerville and Stillwater (LMS, 1978). If the Board of the Hudson River-Black River Regulating District were to develop an implementible program that would reduce flows to less than 340 cu m/s (12,000 cfs), that program would almost certainly conflict with its responsibilities to generate hydroelectric power, to maintain navigable flows, and to protect the recreational value of Great Sagandaga Lake. Therefore, this new alternative could only be 2-8 MQNS 009805 Table 2-4 Comparisons of Flow Contributions Location of Source Average rFolows3 cu m/s (cfs) Percenc of Flow at Fort Edward 100-Year Flood (April 2, 1976)b cu m/s (cfs) Percent of Flow at Fort Edwsrd Lake Luzerne, Hadley Conklingville On Other inflows 2 Fort Edward 81 (2,850) 32 (1,130) 1 (20) 114 (4,000) 71.0 28.0 1.0 100 883.6 (31,200) 229.4 20 <8,100)1 (700) 1,133 (40,000) 78 20 2 100 Notes: 1. The maximum discharge from Conklingville Dam since its construction in 1930 occurred on July 1, 1968, with a release of 377 cu ra/s (13,300 cfs)(USGS, 1975). 2. Ten percenc of the time the flow exceeds 280 cu m/s (10,000 cfs). One percent of the time the flow exceeds 590 cu m/s (21,000 cfs) (LMS, 1978). Sources: a. USGS, 1975; LMS, 1978. b. USGS, 1980. HQHS 009806 Table 2-5 Average PCBs in the River Mater Coluyn between Schuylerville and Stillwater Flow cu m/s Ccfs) 2 PCB Concentration ug/l Cppb) 28 57 142 198 283 340 425 566 708 849 (l.ooo) (2,000) (5,000) (7,000) (10,000) (12,000) (15,000) (20,000) (25,000) (30,000) 1.0 0.7 0.5 0.3 0.07 0.3 0.5 1.0 3.0 5.0 cu (0.7) (0.5) (0.3) (0.07) (0.3) (0.5) (1.0) (3.0) (5.0) Notes: 1. October 1977 through October 1979. 2. From Figure 2-1. PCB Load kg/d (lb/d) 2.4 3.4 6.1 5.2 1.7 8.8 18.2 48.6 182.3 364.9 (5.3) (7.6) (13.5) (11.4) (3.8) (19.3) (40.1) (107.1) (402.0) (804.5) 2-10 HONS 009607 Figure 2-1 River Flows and PCB Concentrations ( /*") 134 H i l l H i l l HONS Note: Arrow (1) indicates percent (?) of time flow not exceeceo Source: MPI, 1980d 009600 used as s short-term mitigating measure that would not eliminate the adverse impacts of leaving the PCS hot spots in the upper Hudson River. In summary, control of river flow is not a feasible long-term alternative. 3. IN-RIVER DETOXIFICATION Alternatives discussed under this heading include: e degradation by ultraviolet ozonation s chemical treatment t bioharvesting s activated carbon adsorption 3A. Degradation by Ultraviolet Ozonation Ultraviolet (UV) ozonation is commonly used for end-of-pipe treatment for the water column. Although new uses for UV ozonation are being studied (Valentine, 1981), they are still at the laboratory stage and are being developed for end-of-pipe water treatment. This alternative does not seem feasible for in-river treatment of sediments, but it should be assessed for treatment of runoff from the proposed containment site. 3B, Chemical Treatment In-river chemical treatment of PCB-contaminated sediments has received little attention. The draft SEQRA EIS indicates that this alternative is infeasible (MPI, 1980d). 3C. Bioharvesting Both Korstman (1977) and MPI (1980d) conclude that bioharvesting is not a feasible slternative. The technique involves harvesting ail the aquatic organ isms in the Hudson River that have accumulated high PCB concentrations and disposing of them in an environmentally acceptable manner. Estimates project that this method would require anywhere from 100 to 10,000 years to complete. 2-11 M0NS 009809 3D. Activated Carbon Adsorption Activated carbon has an affinity for organic molecules and a large surface to volume ratio that lends itself to effective removal of PCBs. Activated earbon processes are widely used in treatment of industrial wastewaters and drinking water. Most of these systems, however, consist of a column containing the acti vated carbon through which the wastewater is passed. The alternative for removal of PCBs from the Hudson River involved a pro posal to utilize a granular magnetized activated carbon media that would be applied to the bottom sediments as a slurry. The retrieval would be accomplished with a continuous belt-type collection device similar to those employed in magnetic separators attached to a barge. The cost for PCB removal utilizing this alternative was estimated to be in the range of $122/ha to $1,215/ha ($300/a to $3000/a). This cost is very reason able when compared to other alternatives. However, this cost does not include costs for storage or destruction of the contaminated carbon. In addition, this alternative has never been tested in-river. Little is known about its effective ness or technological feasibility (Horstman, 1977). 4. DREDGING ALTERNATIVES--THE FULL-SCALE PROJECT The original project presented in the draft SEQRA EIS by NYSDEC included six major components. One component specified the dredging of all 40 hot spot areas in the river bed and containment of the spoil in a secure, upland site. The dredging was to take place over a two-year period. During the first year, the 20 hot spots in the Thompson Island Pool were to be dredged either by hy draulic or by clamshell methods, and remnant deposit areas 3 and 5 were to be completely or partially removed by truck. At the end of the first season, the used portion of the containment area would be covered. During the next year, the lower pools were to be dredged (clamshell dredging/hydraulic pumpout unloading), and the remainder of the containment area waa to ba covered and sealed. In addition, the temporary earthen baains on the containment site would be demoli shed and these areaa regraded. The full-scale alternative will remove approxi- 2-12 MGNS 009810 aately 44 to 49 percent of the PCBs from the river end will result in the trans port of 47,500 kg (104,800 lb) of PCBs into the estuary over the next 21 years (Table 2-6). 5. DREDGING ALTERNATIVES--THE REDUCED-SCALE PROJECT A preliminary review of the costs associated with the original proposal indicated that, in order to meet the federal funding limitation imposed by Con gress, major elements of the original project would have to be deleted. Accord ingly, NYSDEC and its consultants proposed a reduced scale project that modified the original project by reducing the number of hot spots to be dredged and reducing the capacity of the containment site (Appendix B). The Thompson Island Pool was selected as the first pool to be dredged because the cost analysis indicated that this pool had the lowest transportation and treatment costa per pound of PCBs removed. In addition, PCB locations and concentrations have been studied to a greater detail in this pool than in any other. Under the reduced scale project, final selection of the hoc spots to be dredged in the lower pools would await the results of the proposed probing end sampling program to be implemented in 1981. It appears at this time that between 119,000 to 203,000 cu m (155,000 to 265,000 cu yd) of contaminated material could be dredged in the lower pools within the budget constraints. This volume can be better defined after the first season of Thompson Island Pool dredging. The reduced scale alternative will remove approximately 30 to 35 percent of the PCBs from the river and will result in the transport of 61,200 kg (135,000 lb) of PCBs into the estuary over the next 28 years (Table 2-7). The original project deferred final selection of the dredging methodology until after the competitive bidding for the dredging. However, the reduced scale project cost constraints may dictate che use of a clamshell dredge with hydraulic pumpout systems in the Thompson Island Pool in order to ensure that sufficient funds remain to allow construction and amortization of special equipment that would be required for lower pools. 2-13 HONS 009811 Period Table 2-6 PCB Transport: 1 Full-Scale Alternative Average Annua^ PCB Load at Troy kg/yr (lb/yr) Condition 1977 to 1978 1979 to 1983 1984 to 1985 1986 to 2001 After 2001 3,600 (8,000) 3,270 (7,200)3 3,270 (7,200)3 1,950 (4,300) 0 (0) Before remnant deposit actions 5 years until full-scale action is completed 2 years additional to exhaust supply above Lock 7 16 years additional to exhauat supply between Lock 7 and Troy Supply exhausted above Troy 1901 to 2001: 47,500 kg (104,800 lb) of PCB transported into estuary. Notts: 1. Assumes 45 percent removal of PCBs from river by full-scale action. Assumes volatilization rate of 680 kg/yr (1,500 Ib/yr) of PCBs from the upper Hudson River before full-scale action is completed. this rate is the average volatilization between 1981 and whatever year no PCBs remain in the upper Hudson River, or 1/2 the current volatili sation rate. Assumes volatilization rate of 375 kg/yr (825 lb/yr) of PCBs after full-scale action is completed. Assumes routine channel maintenance removal of 1,100 kg/yr (2,500 lb/yr) of PCBs before full-scale action is completed. This removal rate is the average rate between 1981 and whatever year no PCBs remain in Che upper Hudson River, or 1/2 the current removal rate. Assumes routine channel maintenance removal of 625 kg/yr (1,375 lb/yr) of PCBs after full-scale action is completed. 2. Loadings do not reflect yearly fluctuations of river discharges and variations of the PCB mass transported. 3. Assumes contribution from remnant deposit is negligible. 2-14 HONS 009012 Period table 2-7 PCB Transport: Reduced-Scale Alternative 1 Average Annual CB Load at Troy kg/yr (lb/yr) Condition 1977 to 1978 1979 to 1983 1984 to 1985 1986 to 2008 After 2008 3,600 (8,000) 3,270 (7,200)23 3,270 (7.200)3 1,950 (4,300) 0 (0) Before remnant deposit actions 5 years until reducedscale action is completed 2 years additional to exhaust supply above Lock 7 23 years additional to exhaust supply between Lock 7 and Troy Supply exhausted above Troy 1981 to 2008: 61,200 kg (135,000 lb) of PCB transported into estuary. Notea: 1. Assumes 30 percent removal of PCBs from river by reduced-scale action. Assumes volatilization rate of 680 kg/yr (1,500 lb/yr) of PCBs from the upper Hudson River before reduced-scale action is completed. This rate is the average volatilization between 1981 and whatever year no PCBs remain in the upper Hudson River, or 1/2 the current volati lization rate. Assumes routine channel maintenance removal of 1,100 kg/yr (2,500 lb/yr) of PCBs before reduced-scale action is completed. This remova' rate is the average rate between 1981 and whatever year no PCBs remain in the upper Hudson River, or 1/2 the current removal rate. Assumes volatilization rate of 475 kg/yr (1,050 lb/yr) of PCBs after reduced-scale action is completed. Assumes routine channel maintenance removal of 795 kg/yr (1,750 lb/yr) after reduced-scale action is completed. 2. Loadings do not reflect yearly fluctations of river discharges and variations of the PCB mass transported. 3. Assumes contribution from remnant deposit is negligible. 2-15 MOMS 009813 6. BANK-TO-BANK DREDGING PROJECT Bank-to-bank dredging of sediments from Che upper Hudson River would require a much greater amount of equipment operating over several more years than would the full-scale and reduced-scale proposals. Bank-to-bank dredging would also require a much larger containment site or several containment sites. These requirements would make the design difficult to implement and would interfere with procedures intended to avoid or mitigate adverse environmental impacts. Much of the dredging effort would be needlessly expended in removing uncontmiinated sediments and disturbing productive wetlands. In addition, bank-to-bank dredging is estimated to cost over $250,000,000. Based on these concerns, bank-to-bank dredging is not regarded as a feasible alternative. II. ALTERNATIVE COMPONENTS The following sections of this chapter present a discussion of the components to ehe major action alternatives. The alternative for in-river containment is considered to be applicable to certain hot spots where costs and environmental conditions may make it more desirable than dredging. The remnant deposit alternatives do not involve dredging, but would be implemented in conjunction with dredging of the hoc spots. Contaminated material removed from the remnant deposits would be disposed of at the dredge spoil containment site. The other alternative components, in-river dredging mechanisms and dredge spoil disposal, art related to the complete or partial removal of remnant deposits and/or hot spots. 1. IN-RIVER CONTAINMENT While the remove! of PCBa from the river system is the only permanent remedy for Che presently threatening situation, insufficient funds are available to remove all the hot spots from the river by dredging. Additionally, the dispersed state of the material and the practical limits of existing technology inhibit complete removal of the total PCB contaminated river bed material. In-rivtr containment--the isolation of shallow areas of PCB-contaminated sediment from the 2-16 MONS 009814 main flow of th river--is proposed as a way to control as great an amount of PCBs as possible with the funds available. This alternative is intended to be used in conjunction with a dredging program that would concentrate on the less stable PCB hot spots. The PCB hot spots are unevenly distributed along the upper Hudson River. Some hot spots ere located in the main channel of the river; others are located adjacent to the riverbanks or in protected coves. Only those depositions! areas that are not in the main channel of the river are considered for in-river con tainment . In-river containment can be accomplished by various methods, including earthsn dikes or berms, bulkheads, or sheet piling (Figure 2-2). Dikes or berms are trapezoid-shaped structures that are built parallel to the river benk in waters of suitable depth. The PCB-contaminated river bed material contained between the structure and the shoreline would be isolated from the river. As an added precaution, a clay cap could be placed over Che contaminated river bed material. Wetland vegetation would be planted to stabilize the area further. A less costly variation that may be used for wet lend hot spots is a spur dike. This method consists of riprapping the upstream face of the wetland, Chen build ing a dike off the end of the riprap at an angle to the river flow. This dike would armor the upper one-third of the wetland against strong flow. Riprap should be placed at the downstream end of the dike to prevent scouring (Hudek, USEPA, March 17, 1981). Bulkheading is similar to dikes or berms, except that pilings and sheetings are used. Sheet piling consists of metal sheets driven along the face of the hot spot parallel to the flow direction. The metal sheets interface with one another. Because of the costs, potential navigational hazards, and difficulties involved with the construction of containment struc tures in a dynamic river system, the maximum watar depth at which in-river containment could be uaed is 2 meters (m) (6 feet [ft]) below mean river stage. Furthermore, the hot spots selected for such in-river containment must be in areas with a history of deposition, rather than repeated scouring and aggrada tion. Such areas include (1) backwater or eddy deposits formed behind projecting points of obviously stable land (e.g., with mature tree growth), (2) deposits at 2-17 MGNS 009815 the souths of tributary screams, particularly where they occupy re-entrants in Che wall of the presently active stream valley, (3) areas on the inside of meander bends where depositions! history indicates stability, and (4) areas where spoil disposal from channel maintenance dredging has resulted in partially restricted water flow conditions. In selecting areas for stabilization, strong consideration should be given to the positions of the 500-year and 100-year flood levels and the possible con figuration of the river under these conditions. The tops of structures built for in-river containment will be at the 100-year flood level. A site should be rejected if it appears to be unstable under extremely high river flow conditions. Certain drawbacks are associated with the alternative of in-river contain ment ee discussed above. A cost comparison between in-river containment end dredging is presented in Appendix D. Preliminary indications are that coats involved with berms, dikes, bulkheads and/or sheet piling are approximately equal to the costs of dredging. However, the structures would need maintenance, and a long-term water quality monitoring program would be required in the area of the structures. In addition, a majority of the hot spots are located in arees where the mean river stage is above 2 m (6 ft). Another method of in-river containment would be to cover PCB hot spots in the river (especially deeper pockets) with a plastic liner, silt and rocks. During low and moderate flows the cover materials might prevent resuspension of PCBs; but during high flows, the finer material would be scoured and the plastic liner ruptured, allowing the PCBs to be resuspended. 2. REMNANT DEPOSIT ALTERNATIVES Remnant deposits are the remains of sediments snd debris that accumulated behind the former dam at Fort Edward. The deposits consist of silt, sand, rock fragments, sawdust, slabs, and other wood mill wastes. These deposits also contain contaminants, including heavy metals snd PCBs that accumulated in quiescent areas behind the dam. After the dam was removed in 1973, most of Che accumulated sediments were washed downstream. The five deposits that remained 2-18 HONS 009816 HONS 0 0 9 8 1 7 FIGURE 2-2 IN - RIVER CONTAINMENT ALTERNATIVES were left above normal river levels because removal of the dam substantially reduced water levels (MPI, 1980d). Locations of the five remnant deposits are shown on Plate 2. From 1974 to 1975, the remnant deposits were subjected to the following remedial measures: Work Area No. 1: No action a Work Area No. 2: Bank shaping and seeding of 730 linear m (2,400 linear ft) e Work Area No. 3: Bank shaping, placement of rock from timber cribs, and seeding of 600 of 950 linear m (2,000 of 3,100 linear ft) of bank subject to scour e Work Area No. 4: Bank shaping, placement of rock from timber cribs, and seeding of 600 linear m (2,000 linear ft). e Work Area No. 5: Bank shaping, placement of dumped rock fill, and seeding of 340 linear m (1,100 linear ft) During April, 1976, a once in a 100-year flood caused an additional 200,000 cu m (260,000 cu yd) of material to be scoured from the Fort Edward Fool. Remnant deposits 4 and 5 remained intact, but substantial amounts of material were eroded from deposits 1, 2, and 3. In September, 1978, 10,700 cu m (14,000 cu yd) of material were excavated from deposit 3A and moved Co the new Moreau landfill. These sediments contained an average PCB concentration of approx-* imately 1,000 ug/g (ppm). Additional bank stabilization measures were employed at deposit 3 (MPI, 1980d). The remnant deposit sites have been surveyed and sampled by MPI and NYSDEC to determine the degree and extent of PCB contamination. Estimates of the volume of contaminated sediments, PCB concentrations and total PCB mass were made, and tha results are presented in Tables 2-8a and 2-8b. The disparity between Che Cwo seta of data may be due to different sampling procedures, laboratory techniques, or the possible heterogeneity of the deposits (MPI, 1980d). Despite the discrepancies between the two sets of data in Tables 2-8a and 2-8b, both sets indicate that remnant deposits 3 and 5 contain the highest concentrations and greatest masses of PCBs. The PCBs in deposits 3 and 5 ar 2-19 MGNS 009*18 Table 2-8a Estimated Maas of PCB in Remnant Deposits (metric measure) Estimates by MPI (1978) Deposit Hectares i 2.0 2 3.3 3 4.9 3A1 4.5 4 8.2 5 2.4 Total 25.3 Contaminated Depth (Meters) Contaminated Volume (cubic meters) 1.5 30,800 1.8 59,200 3.0 148,000 0.3 17,700 0.9 74,000 3.0 74.000 399,500 Estimates by NYSDEC (1980) PCB (u*/aram) 1 5 200 1,000 10 225 30 310 30,850 14,120 770 17.340 63,420 1 1.6 2 3.2 3 5.4 0.6 1.5 8.3 9,900 49,300 123,000 20 5 65.3 200 260 8,420 3A 2.4 4 4.9 0.3 0.6 7,400 29,600 1,000 25 7,720 770 4A 5 Total 3.4 1.6 22.52 0.9 2.4 31,400 39,500 290,100 40 1,320 250 10,280 28,970 Removed (Area 3A) 7.720 Remaining 21.250 Notes: 1. The actual 3A area and volume removed in Che Fall of 1978 was 3.3 ha and 10,700 eg m. 2. Acreage recalculated by NYSDEC to include only areas known to be contaminated. Source: MPI, I980d 2-20 MGNS 00901-9 Table 2-8b Estimated Mesa of PCB in Remnant Deposits (English measure) Estiaat es by MPI (1978) Deposit Acres i5 28 3 3A1 12 n 4 20 5 _6 Total 62 Contaminated Depth (Feet) Contaminated Volume (cubic yards) 5 40,300 6 77,400 10 193,600 i 17,700 3 96,800 10 96.800 522,600 Estimates by NYSDEC (1980) PCB (ppm) 70 5 680 200 67,950 1,000 10 225 31,100 1,700 38.200 139,700 1 4.0 2 8.0 3 13.3 3A 6.0 4 12.0 4A 5 Total 8.5 4.0 55.82 Removed (Area 3a) Remaining 2 5 7.5 1 2 3 8 12,900 64,500 160,900 9,700 38,700 51.600 379,400 oo 20 5 65.3 1,000 25 40 250 450 570 18,550 17,000 1,700 2,900 22.650 63,820 17.000 66.820 Notes: 1. The actual 3A area and volume removed in the Fall of 1978 was 8.15 a and 14,000 cu yd. 2. Acreage recalculated by NYSDEC to include only areas known to be contaoinated. Source: MPI, 1960d 2-21 HONS 009820 largely positioned above normal river levels and have concentrations greater than 50 ug/g (ppm). These deposits are therefore fairly suitable for either stabili zation or removal. Remnant deposits 1, 2, 4, and 4A contain lower concentrations of PCBs, below 50 ug/g (ppm), and relatively small total masses of PCBs (MPI, I980d). Remnant deposit 4A is low enough in elevation to be subject to yearly flooding and scouring. Remnant depoeit 1 ia an island with unatabilized banks and consequently, is subject to erosion. Remnant deposit 2 has had limited bank improvement and may also be subject to erosion (Tofflemire, 1980). At present, exact quantities of PCBs leaching or otherwise lost to the river from these deposits are unknown. Of the estimated 3,300 kg (7,200 lb) of PCBs currsntly passing over the Troy Dam each year, the LMS model attributes 730 kg (1,600 lb) to losses from the remnant deposits (LMS, 1979). River monitoring at Rogers Island, immediately below the remnant deposits, indicates an annual downstream PCB transport of 590 Co 1,300 kg/yr (1,300 to 2,900 Ib/yr), on the same order as the LMS loss projections (MPI, 1980d). MPI (1980d) has estimated that PCB losses from the remnant deposits by means other than volatilization are negligible because they have either been stabilized and are not being scoured, or, as with deposit 1, have a relatively low PCB concentration. MPI (1980d) suggests that an unknown upstream source of PCBs, such as an uncharted dumpsite, a sewage discharge, or a direct industrial discharge, is contributing to the present load of PCBs passing Rogers Island. Tofflemire' (1980) projected PCB losses of 200 to 460 kg/yr (440 to 1020 lb/yr) from the remnant deposits, primarily from deposits 1, 2, 4 and 4a. Deposits 3 and 5 were considered to be stable, accounting for less than 2.3 kg/yr (S lb/yr). Tofflemire (1980) estimated that erosion could remove PCBs at rates of 45 to 130 kg/yr (100 to 280 lb/yr) from deposit 1, 60 kg/yr (136 lb/yr) from deposit 2, and 45 to 270 kg/yr (100 to 600 lb/yr) from deposits 4 and 4a. Projections of PCB losses were baaed on the assumption that the deposits would be eroded in time spans of 5 to 30 years. Currently, some of the sand and wood chips eroded from the remnant deposits may be accumulating on the north tip of Rogers Island, in the east channel adjacent to the island, and in the vicinity of buoy 212. Approximately 75,000 cu o (98,000 cu yd) of material was dredged from the channel in 1979. Thus, according to Tofflemire (1980), sediments from Che 2-22 HONS 009821 remnant deposits are still eroding, but it is uncertain which deposit contributes the most PCS*. to date, NYSDEC has not identified the source of the large quantities of PCBs being measured at Rogers IsLand. It remains to be determined whether or not the remnant deposits are releasing substantial amounts of PCBs to the river. PCBs could escape from the remnant deposits by several mechanisms (HPl, 1980d): e scour during high flows (reduced by bank stabilization measures employed to date) e precipitation that infiltrates the deposits, desorbs PCBs and subsequent** ly passes into the river as contaminated leachate runoff from the surrounding terrain, that infiltrates the and desorbs PCBs, and/or erodes the surface deposits deposits e regional groundwater movement through the deposits that may desorb PCBs en route to the river e floods that saturate the deposits and subsequently recede, carrying particle-bound and desorbed PCBs Dust-borne transport by wind during dry periods PCBs are also released from remnant deposit# by volatilisation. NYSDCC estimates that 130 kg/yr (280 lb/yr) of PCBs volatilize from the five deposits, representing a long-term, low-level source of atmospheric PCBs. Other PCB losses from the remnant deposits may occur by microbial degradation within the contam inated deposits and biological uptake to the terrestrial system (MPI, 1980d). An additional loss of PCBs from the remnant deposits could occur if a surging dam were constructed at Fort Edward. The Niagara Mohawk Power Company (NMPC) has considered construction of such a dam to produce hydroelectric power. If the Fort Edward Dam is rebuilt and the deposits are inundated, four additional loss mechanisms to the river may occur (MPI, 1980d): e erosion during the construction phase scour of the deposit surfaces during high flow biological uptake to aquatic system saturation and subsequent drainage of contaminated deposits that are subject to the fluctuating pool levels MOWS 009822 2-23 The proposed alternatives for dealing with the remnant deposits are: (l) no action, (2) denial of access, (3) in place cover, and (4) complete or partial removal. The purpose of the action would be to reduce or eliminate possible losses of PCBs from the deposits to the environment. Ongoing PCB losses and potential losses from high-Clow periods must be considered. 2A. No-Action Undar this alternative component, no remedial work would be undertaken beyond the bank stabilization, seeding, and material removal already completed between 1975 and 1978. Any present losses of PCBs to the river as well as volati1ization of PCBs to the air wouldcontinue. There would be no protection against losses from high river flows or long-term erosion. The no-action alter native component is currently proposed as part of che reduced scale project (Appendix B). 2B. Denial of Access At present, several hot spots are easily accessible to the public from the land, and some are accessible by boat. There is evidence that children occasion ally play on some of Che deposits and that motorcycles are driven over them. Animals also have free access to the sites. Human and animal activity at the sices may accelerate erosional processes and create a potential health risk. The following measures would be taken under this alternative: placement of chain link fences, at least 2 m (6 ft) high, topped with barbed wire, and buried 0.6 m (2 ft) into the ground, on che landward sides of all remnant deposits placement of signs facing the water as well as the land at all remnant sites to warn people that the area contains toxic wastes continued maintenance of the fence and signs seeding of ground disturbed by the work described above and other unvege tated areas with appropriate grasses workers would have to take necessary precautions while at the sites, such as the wearing of respirators and protective clothing This alternative would do little to reduce present losses of PCBs to the water and air and would not prevent potential losses from high flows and long term erosion. 2-24 HONS 009823 2C. In-Place Containment This alternative would entail further bank stabilization and emplacement of an impermeable cover, such as plastic or clay, anchored by a protective blanket of graded material designed to withstand maximum expected flow velocities during floods (MPI, 1980d). Complete encapsulation would also involve placement of a curtain wall to prevent groundwater infiltration and desorption of PCBs. Total amount of capping material needed, the thicknesses of the impermeable layer, the protective blanket of graded materials, and other construction re quirements, as well as costs, are presented in Appendix 0. This alternative component would require extensive construction. Roads would have to be built to the sices for the transport of materials. In-place stabilization and capping of deposits 3 and 5 would require 5,000 to 10,000 truck trips to bring materials to the sites (MPI, 1980d). Implementation of this alternative component would substantially reduce any possible losses of PCBs to the river. It would also protect against scouring during high-flow periods. Volatilization would be essentially eliminated, as would release through airborne dust and biological pathways. If a surging dam were constructed at Fore Edward, this alternative would not prevent losses of PCBs once the deposits became submerged. Fluctuations in water levels and water turbulence behind the dam would eventually destabilize the remnant deposits even if they are capped. This alternative would require s continual maintenance and monitoring program. It would not prevent any long-term erosional changes of the river channel. The remnant deposits would remain a potential, long-term source of PCBs to the river environment. 2D. Complete or Partial Removal Excavation and upland containment of all remnant sites would entail movement of 280,000 cu m (370,000 cu yd) of contaminated material containing some 21,200 kg (46,800 lb) of PCBs. Transport of this material would require 20,000 to 40,000 truck trips. In-place stabilization would not be attempted. This alterna tive would be difficult to implement and would include removal of materials with 2-25 MONS 009824 low levals of contamination. This component would not be cost-effective because it would increase sediment removal volume by 74 per cent while increasing PCB removal mass by only 14 percent, as compared with the partial removal alterna tives described below (MPI, 1980d). The sdvantsge of the complete removal alternative is that it would effec tively remove an estimated one-seventh of all PCBs believed to be in the Hudson River. It would effectively eliminate all future losses of PCBs from the remnant deposit areas to the river and air, which is aspacislly important if the remnant deposits are the presently unknown source of PCBs in the upper Hudson River. Complete Removal of Deposits 3 and 3 In the draft SEQRA EIS (MPI, 1980d), NYSDEC proposed to remove approximately 162,500 cu a (212,500 cu yd) of contaminated material, containing roughly 18,500 kg (41,000 lb) of PCBs from deposits 3 and 5. This material would be transported by truck to the PCB containment site located 4.8 km (3 mi) to the south. Ap proximately 11,000 to 22,000 truck trips would be required to remove the mater ial. NYSDEC proposed no additional remedial measures for deposits 1, 2, and 4, which contain relatively low levels of contamination. However, deposit 4A, containing 1,300 kg (2,900 lb) of PCBs at an average concentration of 40 ug/g (ppm), may be contributing PCBe to the water column, and could be excavated or stabilized further aa part of future remedial work in the area. If excavation of area 4A were to be included aa a component of the overall project, the removal volume would total roughly 193,900 cu m (253,600 cu yd) (MPI, 1980d). Removing deposits 3 and 5 under this alternative would be advantageous because: t they contain the highest concentration and mass of PCBs in the Hudson River s in piece, they represent a potential long-term source of contamination to the lower Hudson River s substantial volatilization occurs from them the cost per pound of PCB removal from the deposits is lowest of any contaminated area in the river 2-26 HONS 009825 Partial Removal Areaa 3 and 5 Two partial removal alternativea for deposits 3 and 5 were considered by NYSOCC and LMS. Under each, removal volumes would be decreased and PCB recovery would be somewhat reduced. The NYSDEC alternative calls for complete removal of deposit 3 to a depth of 2.5 m (8 ft), recovering about 10,300 kg (22,650 lb) of PCBa with 39,500 cu m (51,600 cu yd) of material. At deposit 3, the top 0.5 m (1.5 ft) and/or all material above an elevation of 40 tn (134 ft) would be re* moved, as would all material down to the present water table at the southern 0.6 ha (1.4 a) of the area. Borings taken by MPI at the southern end of deposit 3 indicate that the water table is contaminated in the portion of the deposit. Removal of surface material from 2.5 ha (6.3 a) plus removal of material down to the water table at the southern end would total some 16,700 cu m (21,800 cu yd) and would recover approximately half of the PCBa in deposit 3. A filter fabric and stone blanket could be placed over the entire 5.3 ha (13.3 a) area should conditions warrant (MPI, 1980d). Aa conaultanta to NMPC, LMS has proposed removal of all material abova an elevation of 40 m (134 ft) in deposits 3 and 5. Under this proposal, in the portion of depoeit 3 above en elevation of 40 m (134 ft), 7,800 cu m (10,200 cu yd) of material containing 630 kg (1,380 lb) of PCBa would be removed. Con* t amineted surface materials below an elevation of 40 m (134 ft) would remain unexcavated. Nearly all of deposit 5 lies above an elevation of 40 m (134 ft) and, under this proposal, roughly 26,200 cu m (34,300 cu yd) of material con* taining 9,400 kg (20,780 lb) of PCBs would be excavated from a 1.6 ha (3.9 a) area. Approximately 3,700 to 7,400 truck trips would be required to remove the material (MPI, 1980d). The LMS proposal is coordinated with the proposed reconstruction of the Fort Edward Dam by NMPC. If rebuilt, the dam would create a pool that would fluctuate between elevations of 40.5 and 42.6 m (136 and 142 ft). Use of the 40 m (134 ft) level permits a conservative estimate of the area exposed to the rise and fall of the pool. This rise and fall would tend to wash PCBa out of the deposit and into the water. Excavation to an elevation of 40 m (134 ft) would remove ell contaminated materials subject to this fluctuation (MPI. 1980d). 2-27 HONS 009826 The Advantages of the partial removal of deposits 3 and 3 are: about half of the PCB mass of deposit 3 could be removed by excavating only 13 percent of the contaminated volume e substantially fewer truck trips are needed to remove the material e subsequent lining and capping would seal the remaining PCB in place The amounts of material and PCBs that would be removed by each of the remnant deposit removal alternatives are summarized in Tables 2-9a and 2-9b. 2E. Transportation Alternatives Trucking seems to be the onLy feasible method of transporting materials the 2.4 km (1.3 mi) to and from the containment site (MPI, 1980d). Truck access to deposits 3 and 5 would require the use of residential streets. Methods of transport other than by truck are not feasible. Alternative transport systems evaluated include: riverside conveyer riverside roadway constructed of dumped rock along the bank barge transport, hydraulic pumpout . pipeline with booster stations A conveyor would require material rehandling and is unsuitable for certain materials found at the remnant deposit sites. Barge transport alone is not feasible because the river is unnavigable above Lock 7. All other alternative means for transporting the remnant deposit materials mentioned above would have associated costs 3 to 20 times those of the proposed transport by truck (MPI, 19800). 3. IN-RIVER DREDGING MECHANISMS This section will evaluate the three major dredging/transport systems: a clamshell dredging/mechanical unloading clamshell dredging/hydraulic pumpout unloading s hydraulic dredging and transport 2-28 HONS 009827 Table 2~9a Remnant Deposit Removal Alternatives (metric tneaaure) Deposit Complete Removal All Deposits CU IB kg Complete Removal Deposits 3 and 5 cu ra kg Partial Removal . NYSDEC ' cu m kg Pareial cu m kg 1 9,900 200 - -- 2 49,300 260 - -- 3 123,000 8,420 129,900 8,420 16,700 3,760 7,800 630 3A 7,400 (Removed to upland containment (1978)) 4 29,600 1,300 - -- 4A 31,400 1,320 - -- 3 39,500 10,280 39,500 10,280 39,500 10,280 26,200 9,400 Tool 290,100 21,780 169,400 18,700 56,200 14,040 34,000 10,030 Notea: 1. Includes removal of the surface 0.5 m (1.5 ft) of material over 2.5 ha (6.3 a) of deposit 3, 0.9 m (3 ft) cut over southern 0.6 ha (1.4 a) of deposit 3, 5.3 ha (13.3 a) of liner and capping material. Complete removal of deposit 5. 2. Includes removal of all material to elevation 40 m (134 ft) in deposits 3 and 5. Does not include additional excavation in deposit 5 for a new hydroelectric dam. Source: MPI, 1980d. 2-29 MOMS 009628 Table 2-9b Remnant: Depo.it Removal Alternatives (English measure) Deposit Complete Removal All Deposits Comp le t e Removal Deposits 3 and 5 Partial Removal NTSDEC(1) Partial Removal lms<2) cu yds lb cu yds lb cu yds lb cu yds lb i 12,900 450 - -- 2 64,500 570 - -- 3 160.900 18,550 169,900 18,550 21,800 8,275 10,200 1,380 3a 9,700 (Removed to upland containment (1978)) 4 38,700 1,700 - -- 4A 41,100 2,900 - -- 5 51,600 22,650 51,600 22,650 51,600 22,650 34,300 20,780 Total 379,400 46,800 212,500 41,000 73,400 31,925 44,500 22,160 Notes: i) Includes removal of the surface 1.5 foot of material over 6.3 acres of deposit 3, a 3 ft cut over southern 1.4 acres of deposit 3, 13.3 acres of liner and capping material. Complete removal of area 5. 2) Includes removal of all material to an elevation of 134 ft in deposits 3 and 5. Does not include additional excavation in deposit 5 for a new hydroelectric dam. Source: MPI, 1980d. 2-30 HONS 009829 In addition, other dredging systems have been evaluated by MPI (1978b, 1980c) and Gahagan and Bryant (1980) and will be discussed briefly. The following descriptions of the various major dredging alternatives were obtained from various reports prepared by MPt (1978b, 1980c, 1980d). 3A. Clamshell Dredging/Mechanical Unloading The clamshell dredging/mechanical unloading system consists of barge-mounted cranes outfitted with suitable clamshell buckets to excavate the bed material (Figure 2-3). The excavated material is loaded on hopper scows for transport to a rehandling area. At the rehandling area, the material is unloaded from the scows utilizing crawler-mounted clamshell buckets and loaded on sealed-body dump trucks for transport to the containment site (Figure 2-4). Alternatively, a belt conveyor system could be used to transport Che sediments from the rehandling area to the containment site. However, the conveyor would have to be protected from the weather, and spillage may be a problem. The water treatment plant at the containment site is sized for 3,785 cubic meters per day (cu m/d) (1 million gallons daily (mgdl) and will treat runoff from the site and any rainwater that falls on the site. In addition, runoff rainwater from the rehandling area will be treated. Because of the quantity of material that will be hauled to the containment site, approxiately 400 15.3-cu m (20-cu yd) truckloads per day will be required. Hauling will be a continuous, 24-hr a day operation, and the traffic-routing problems and environmental impacts will be substantial. In addition, the cost associated with this system is greater than the other major dredging alterna tives. Difficulties associated with handling oud and fine-grained material in the dredged sediment will hamper the unloading operation. None of the dredging contractors contacted were interested in unloading the barges mechanically (MPI, 1980d). Consequently, this system was eliminated from further consideration. 38. Clamshell Dredging/Hydraulic Pumpout Unloading This system, shown in Figure 2-4, utilizes the same equipment in the river as described above for the clamshell dredging/mechanical unloading alternative. At the rehandling area, however, a barge-mounted hydraulic pumpout system will be used to unload the hopper scows. The pumpout plant can be operated as a onee- 2-31 MONS 009830 through process or as a recycle system. River or recycled water from the die* posal site would be mixed with the sediment in the hopper scows to an average 15 percent slurry. The slurry is Chen pumped to the disposal area. The water treatment plant is sized for approximately 37,850 cu m/d (10 tngd) in a oncethrough system and 3,785 cu m/d (1 mgd) if pumpout water is recycled. At the disposal area, the position of the slurry-pipeline discharge and the layout of the interior dikes would be arranged to facilitate the mixing of fine and coarse-grained sediments. The factors that affect the excavation of material from shallow areas with a clamshell dredge include the weight and configuration of the clamshell bucket, material stratification and characterization, and caving of the cutting face, as well as the placement of the bucket and general skill of the operator. If soft material is encountered, the clamshell bucket can readily penetrate the layers. The bucket will generally scrape across compacted layers of material that lia below the contaminated sediments in the hot spots. The clamshell bucket design can be modified to provide more efficient excavation and recovery of PCBs. Some modifications chat should be considered in the dredging design phase of the project are: lateral digging bucket special seals on the bucket lipa buckets Chat close completely shrouded or hooded buckets that would prevent washout of material during hoisting Clamshell dredges are readily available and have been used for many years (Gahagan and Bryant, 1980). Hydraulic pumpout plants have been used both in this country and in Europe. This system is implementable, and competitive bids could be submitted because several local contractors are equipped to do Che work. The estimated PCB losses from dredging with this system are presented in Table 2-10. The total loss ia dependent on the magnitude of return water flow. If pumpout water ia recycled and the return water flow is treated by sedimenta tion and coagulation, PCB losses from this system are approximately 0.01 percent. In a once-through process, the return water flow is estimated to be 37,850 cu m/d 2-32 HONS 009631 HYORAULIC CUTTERHEAD DREDGE CLAMSHELL DREDGE MUD CAT DREDGE Figure 2-3 Dredge Illustrations Source: MPI, 1980d HONS 009832 CLAMSHELL DREDGING - HYDRAULIC PUMPOUT' Figure 2- 4 Alternative Dredging Systems Source: KPI, 1978 b HONS 009833 Table 2-10 PCB Losses Clanahell Dredging/ Hydraulic Pumpout Unloading Loss Mechanism Missed during dredging ^ Lost in dredging progress 2 Lost in return water flow at (10 ug/1) PCB Loss (percent) 5 0.8-4 0.01-0.1 Notes: 1. If the PCB lose in the dredging process does not resettle in down stream hoc spot areas, the total loss from this mechanism could be 4 percent. However, if 20 percent of the PCBs desorb and the remaining PCBs resettle in hot spots to be dredged, the loss from this mechanism could be only 0.8 percent. 2. Treatment by coagulation and sedimentation. Source: MPI, 1980a. 2-33 MONS 009834 (10 mgd), and PCB losses are 0.1 percent. The total PCBs recovered are estimated to range between 90.9 and 94.2 percent for Thompson Island Pool dredging with this system. It is believed that these losses will not be exceeded if the dredging and disposal operations are carefully controlled. Lab work is currently underway to determine more accurately the effluent PCB concentrations to be expected with sedimentation-coagulation treatment. 3C. Hydraulic Dredging and Transport The equipment utilized in a hydraulic system would be a conventional cutter head suction dredge assisted by boosters, tugs, barges, and miscellaneous equip ment (Figure 2-3). Material would be transported by floating or submerged pipeline to the shoreline (Figure 2-4). A channel trench for sections of sub merged pipe might be necessary to avoid any obstruction to navigation. A hydraulic dredging operation in the Thompson Island Pool would require one booster station. Removal of lower pool hot spots by this method would require a number of booster stations and an unwieldy pipeline system. Because of high coats associated with booster stations and long pipelines, this system is appli cable only to work in the Thompson Island Pool. Tha slurry would be pumped on land from the river to the containment itc. It would be necessary to install the pipeline beneath U.S. Route 4. At Che disposal area, the slurry discharge and dikes would be arranged ea de scribed for the clamshell pumpout alternative to facilitate mixing of fine and coarsa-grained material. The water treatment plant would be sized for approximately 37,850 cu m/d (10 mgd). Equipment required would include one 40-cm (16-in) hydraulic cutter head dradge, one derrick berge, two 40-cm (16-in) booster pumps, two bulldozers, one small tug, one tender tug, one fuel barge, one work barge, pipeline, and miscel laneous machinery (Gahagan and Bryant, 1980). This system offers the advantage of one-time handling of the material between the dredging operation and the disposal area. For the Thompson Island 2-34 HONS 009835 Pool, Che system is economically competitive with a clamshell dredging/hydraulic pumpout system. Hydraulic dredges of this nature are in regular use on the Hudson River by the NYSDOT end others, end no difficulty is expected in securing equipment of this type. The design of hydraulic dredges must be modified to improve PCB recovery efficiency by: installation of a shroud to enclose the top portion of the cutter use of sensor devices to control depth of cut over an uneven bottom a modification of the conventional cutterhead dredge by installing a dustpan-type head These modifications will be considered and incorporated as appropriate in the dredging design phase of the proposed project. The estimated PCB loases expected with the hydraulic dredging and transport system are presented in Table 2-11. For hydraulic dredging, the loss from return water flow is larger Chan for the clamshell dredging/pumpout system with recycle of return water because of the larger flow requiring treatment. For Thompson Island Pool dredging, the average return water flow will be 37,850 cu m/d (10 agd) as compared to 757 cu m/d (0.2 mgd) with the pumpout recycle system. The loss in return water flow with sedimentation and coagulation treatment is estimated at 0.1 percent and is not significant when compared to the other loss mechanisms. Therefore, the total PCBs recovered are estimated to range between 95.9 and 97.5 percent. It is believed that these losses will not be exceeded if the dredging and disposal operations are carefully controlled. As stated pre viously, lab work is underway to define more clearly the effluent PCB concentra tions with sedimentation-coagulation treatment. 3D. Other Dredging Systems Several ocher dredging systems have been evaluated by MPI and Gahagan and Bryant, and the difficulties with these alternative systems, including the reasons for their rejection as primary dredging systems, are summarized below: 2-35 HONS 009836 Table 2-11 PCB Losses: Hydraulic Dredging and Transport Loss Mechanism Missed during dredging ^ Lost in dredging process ^ Lost in return water flow at (10 ug/1) PCB Loss (percent) 2 0.4-2 0.1 Note*: 1. If the PCB lost in Che dredging process does not resettle in down stream hot spot areas, the total loss from this mechanism could be 2 percent. However, if 20 percent of che PCBs desorb and the remaining PCBs resettle in hot spots to be dredged, the loss from this mechanism could be only 0.4 percent. 2. Treatment by coagulation and sedimentation. Source: MP1, 1980a. 2-36 HONS 009837  Mud cat dredge: low capacity, limited pumping distance, and inability to deal with large debris. This dredge is illustrated in Figure 2*3. Although not applicable to the whole project, it does have advantages for limited work in shallow areas. Dustpan type dredge: difficulty with large debris, ineffective with an uneven bottom, and requires use of water that might cause PCB dispersion. Not presently available, although a conventional hydraulic dredge could be modified to operate as a dust pan. The Norfolk (Virginia) District of che USACOE proposed to carry out a demonstration project with a con** verted dredge in 1981. Pneumatic dredge: limited pumping distance, limited capacity, difficul ties with large debris, limited availability, and poor fuel economy. Reported capacities of approximately 60 cu m/hr (2,000 cu ft/hr) for one proprietary type would quadruple cost of dredging. Backhoe or dragline dredge: difficulties with bucket roll that could cause displacement of PCBs, imprecise control of dragline bucket, and turbidity. a Cable excavator: requires extensive operations on the shoreline, is difficult to control, and causes turbidity and dispersion of PCBs. Pumping into scows: poor economically because of large volume of water to be transported and rehandled. a Buckat ladder dredge: not available; causes dispersion of sediments. These systems may be applicable for hot spots in shallow areas or other inaccessible locations. 4. DREDGE SPOIL DISPOSAL Associated with any dredging alternative is disposal of the dredge spoil. 2-37 HONS 009838 Two alternatives ere considered for the disposal of the contaminated material. One alternative involves the ultimate disposal of the dredge spoil through a detoxification method. The other option is land disposal in a secure containment facility. NYSDEC screened 40 potential sites in the upper Hudson River area and selected a tract of land located 4.0 km (2.5 mi) south of the Village of Fort Edward. On this site an earthen structure will be built to contain the con taminated sediments. This site is intended for temporary disposal of the dredge spoil until an economical ultimate disposal method is developed. The criteria used for sice selection assumed indefinite long-term storage to ensure site safety. 4A. Detoxification Alternatives evaluated under this section included: physical destruction through incineration e chemical treatment biodegradation Currently, physical destruction through incineration is the most effective and best understood means of ultimately destroying liquid PCBs. Most of the systems used, however, remove PCBs in Che liquid phase and are not suitable for PCB-contaminated sediments. The systems require high temperatures (l,148c (2100Fi) and carefully calculated detention times in order to minimize impacts to air quality. During research of different alternatives, GE, with the assistance of KYSDOT, collected contaminated sediments and sent them to a pyrolysis system in New Jersey. The conclusion of this study (Nichols Engineering end Research Corporation, 1978) were as follows: e PCB-contaminated Hudson River bottom sediment can be decontaminated by heating the solids in a multiple-hearth furnace to a temperature of about 537C (1,000F). Both incineration and pyrolysis are successful methods of decontamination. 2-38 HONS 009839  Pyrolysis is preferred over incineration for toxic heavy metals retention in the solid phase. Scrubbers are relatively ineffective for reducing the air pollution discharges of heavy metals, particularly cadmium and lead, from incinerator stacks (Farrell and Wall, 1981). e Afterburner temperatures between 871 and 982c (1600 to 1800f) will be required to destroy the volatilized PCBs. The cost for this type of incineration of PCB-contaminated dredge spoils has been estimated to be approximately $130/cu m (3100/cu yd), including construction of dewatering equipment and an incinerator (MPI, L980d). Because of the large volume of materials that would have to be processed, incineration of contaminated Hudson River sediments is economically infeasible. Incineration costs for dredge spoils, not including dredging and transportation costs, would exceed $200,000,000 for the full-scope plan and $80,000,000 for the revised plan. The cost for pyrolysis is comparable to the cost for incineration. Other systems capable of incinerating PCBs exist. The Wright Malta Corpora tion (1979) claims to have developed a bench-scale steam gasification process that may potentially convert PCBs into relatively innocuous by-products such as fuel gas and salt. However, this process has been demonstrated to be applicable to PCB-contaminated sediments on a laboratory basis, and the effectiveness and economics of this system have not yet been justified. Rollins Environmental Services in Deer Park, Texas, and Energy Systems Company in El Dorado, Arkansas have received permits to incinerate waste con taining PCBs as of April, 1981 (Jordan, Rollins Environmental Services, February 26, 1981). At present, their system will handle only liquid wastes, and costs have been estimated to range from $0.06 to $0.99/kg ($0.Q3-$O.45/lb) of waste. Currently, chemical and biological degradation of wastes are not well proven and remain at the laboratory stage. Chemical degradation has been successful with pure PCBs in laboratory studies (MPI, 1980d), but large-scale degradation has not yet been proven feasible. A chemical process has been developed by the Coodyear Tire and Rubber Company (Coodyear, 1980) that reacts sodium metal with 2-39 HONS 009890 PCBs C high temperatures (350C 662Fl). The process is slow and is carried out in an autoclave. It is still in the laboratory stage and is not feasible for the Hudson River sediment at this time. ' Biological degradation of some PCBs (the lower aroclors) has been found to be successful by GE. Five types of microorganisms demonstrated the ability to degrade PCBs. Much work, however, is still required before a suitable micro organism is found that can degrade PCBs in a reasonable time span. Sunohio has developed a process called PCBX that has been demonstrated to detoxify typical transformer oil and may be suitable for other PCB-contaminated oils (Sunohio, 1980). This process is not designed to detoxify PCB-contaminated river sediments. 4B. Containment in Upland Disposal Site Because of the limitations associated with dredge spoil detoxification, a site for a secure containment facility was sought (MPI, 1980a). MPI evaluated the regional geology, hydrology, soils, land use, and development patterns in the upper Hudson River Valley in an attempt to find a suitable location for a con tainment facility. A screening methodology was developed that incorporated federal and state regulations for secure land burial facilities, the nonavail ability of mineral resources that may be mined at some future date and site preparation requirements to achieve acceptable conditions in an economical manner. The process used in applying this methodology and the site screening criteria are described in various MPI reports (1978b, 1978b, 1980d). Initial screening resulted in 40 potential parcels that were subsequently reduced to 12 sites. Field inspection further reduced the number of potential sites to 4. After detailed screening of the environmental and socioeconomic factors present at each site, one site was selected. This site is identified as Site 10 and is located 4.0 km (2.5 mi) south of the Village of Fort Edward. The tract consists of three parcels totaling approximately 100 ha (250 a) bisected by a north-south oriented power line right-of-way. Access to the property is 2-40 HONS 009841 from Route A to the west. Elevations at the site range from 55 m (180 ft) in the northwest to AO m (130 ft) in the southeast along Dead Creek. Most of the site is at elevations between A-A and A7 m (IAS and 155 ft). Detailed comparisons of the final A candidate sites are contained in various MPI reports (1978b, 1980a, 1980b). _ Upon selection of Site 10 as the location for the containment facility, a detailed geotechnical and environmental study was performed on the site (MPI, 1980a). The field investigation indicated that subsurface conditions were adequate to prevent leachate from migrating off-site. Soils found at Site 10 are characteristically deep, moderately well drained to poorly drained fine-textured soils. The underlying clays are proglacial lake beds consisting of varved clays. Laboratory and field tests indicate that the clays are very poorly permeable. Permeability of the clays ranged from 2.5 x 10 ^ to 5.88 x 10 ^ --8 --6 cm/s (9.8 x 10 to 2.3 x 10 in/s). Additional investigations included 26 borings, four resistivity traverses, and 19 test pics. Information provided by these surveys indicates that the site is adequate for Che secure land disposal of PCB-contaminated sediments. With the selection of Site 10 as the land disposal site, a secure contain ment facility was designed to encapsulate the contaminated sediments. MPI has designed engineering structures and control systems to prohibit leachate movement and provide continuous monitoring during the placement of the dredge spoils and after closure. All of the containment dikes, berms, and permanent cap will be constructed primarily of the silty clay and silty clay loam soils present on the site. Engineering studies on the soils at the site indicate that this aatarisl will form dikes that are stable if built to design specifications. A seepage analysis of the dike material indicates that flow would be on the order of 2.5 x 10 ^ cu m/d/m (3 x 10 cu ft/d/ft). It is estimated that water within the containment area would require in excess of 1,000 years to reach the outside face of the dike (MPI, 1980b). When placed in the proposed containment site, the dredged material will contain substantial quantities of interstitial water remaining as a result of the 2-A1 HONS 0098*4 hydraulic transport process. The race at which this liquid can be drained is a function of Che permeability of the dredged material, and drainage will take from 1 to 2 years at the maximum. It is estimated that this will produce 344,435 cu m (91,000,000 gallons [g]) of interstitial water over the 1 to 2 year period. An alternative method of dewatering the dredge spoils is to use hydrocyclone separators, diaphragm presses, or other mechanisms. The dewatering spoils would be deposited in an upland containment site and the water would be dis charged to the Hudson River after receiving necessary treatment. This conceptual alternative is more energy intensive than the alternative to dewater by gravity, but impacts associated with volatilization of PCBs during dewatering probably would be substantially less using mechanical methods. However, the engi neering feasibility and design of mechanical dewatering have not been deter mined. Nevertheless, applying currently available dewatering processes, such as hydrocyclone separators or diaphragm presses, preliminary estimated indicate that mechanical dewatering would cause additional costs of more than $5,000,000 (Richard Thomas, Project Manager, MPI, April 21, 1981). Therefore, mechanical devstering is presently regarded as not cost-effective. Long-term rainfall infiltration through the cover could continue to generate a leachate, estimated to be approximately 8,377 cu m/yr (2,200,000 gal/yr) (MPI, 1980b). A leachate collection system has been designed by MPI for the contain ment facility and consists of the following components: sloped bottom of containment area gravel-filled collection trenches wrapped with filter fabric perforated drainage piping in the collection trenches collection and sampling wells on the containment area perimeter con nected to Che drainage piping piping system to connect the drainage system to a discharge point at the Hudson River e flow metering and monitoring system The leachate collecting system would be valved. Discharge to the Hudson River would be permitted only if leachate quantities and concentrations observed will have no adverse impact on the river. 2-42 HONS 009843 Stormwater runoff collection would entail the use of one collector drainage channel, constructed at the toe of the containment dikes, to convey all off-site and on-site drainage to the Hudson River. After closure, additional channels would be constructed both along the south dike and on top of the closed contain* ment areas. Ail flow from these channels would be conveyed to the collector drainage channel by means of drop pipes constructed at various locations around the containment areas. All flow from the collection channel, as well as effluent from the treatment plant, would be conveyed to the Hudson River under Route 4 and the Champlain Canal by means of a closed conduit (KPI, 1980b). During each dredging season, the proposed sice would receive spoil from the dredging operations. At this time, Che rate at which the dredged material dawaters will dictate how quickly the cap will be placed. The higher the per* ccntage of fine-grained sediments, the slower the material will drain. Recent data from probings in the Thompson Island Pool indicate that the material will dcwatar within two or three weeks of placement. Based upon this initial assump tion, the capping material will be spread over the dredged material as dredging progresses throughout the summer. This will minimize volatilization. At the end of the second season, the site will be permanently capped. The cover will consist of a 46-cm (I8*in) thick layer of clay overlain by gravel and topaoil. Clay material for the cap will be obtained on-site. The cap will be designed to withstand deterioration by freezing, thawing, and drought. At the time of permanent closure, all return water treatment structures will be removed and permanent long-term monitoring and control structures will be installed. Under the full-scale project, the containment area was designed for a capacity of 1,728,000 cu m (2,260,000 cu yd) of contaminated material. Under the reduced-scale project, the required containment volume was reduced owing to deletion of remnant deposit relocation and containment, deletion of provisions for NYSDOT spoil area containment, and reduction in hot-spot dredging. For these reasons, the required containment capacity of the reduced-scale project is estimated to be 841,000 cu m (1,100,000 cu yd) (Appendix B). 2-43 HONS 009644 III. SELECTION OF THE RECOMMENDED ACTION 1. RECOMMENDED ACTION Based on public health, environmental, coat, and engineering evaluations carried out by EPA and its environmental consultants, the EPA recommends that the action alternative be implemented if contingency/mitigation measures ensuring public safety are developed (Table 2-12). Resolution of these issues will ensure that minimal risk to public health, safety, and welfare will result from the implementation of this project Modi fications and contingencies developed wilL be submitted for public comment before a NEPA decision is reached. EPA recommends that a project to dredge and/or stabilize all known PCB hot spots be implemented. After carefully evaluating both the original full-scale proposal and reduced-scale proposal subaittted by NYSDEC, EPA recommends funding modification of the original full-scale project since greater potential benefits will be realized. However, if additional funding is not available, the reduced-scale project is also recommended, although with reduced potential benefit, because it will provide for demonstration of river recovery and in definite storage while not endangering public health, safety, and welfare. The authorization by Congress under Section 10 of the CWA Amendments is $20,000,000. If the action alternative is approved, the recommended action is to undertake the originally proposed $40,000,000 full-scale project with the required modifications. Additional funds from either federal, state, or perhapa outside sources will be required to implement 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 recommended chat the $26,700,000 reduced-scale project could be undertaken along with the aforementioned project modifications. 2-44 y MOWS 009845 Table 2-12 EPA Reconmendcd 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 contaminated material Deletion of remnant deposit removal and upland containment; instead, provision of secure cap and top dressing,and further bank stabilisation if necessary Elimination of provision for the con tainment of PCB-contaminated material from dumpsites in the Fort Edward area. Proviaion for containment of contaminated materials from three NYSDOT dredge spoil sites (212, 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/enviTonmcntal 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 2-45 HONS 009846 2. FINDINGS 1. Disposal of PCB-contaminated dredge spoils in e landfill would provide a higher standard of protection of the public health, safety, and welfare than disposal of such pollutants by other methods including, but not limited to, incineration or a chemical destruction process. The basis of the above conclusion is that alternative disposal methods are either infeasible or highly speculative and would render the entire project economically infeasible within the amounts of money available for the "rescoped" project (i.e., $26.7 million). 2. The proposed containment site, incorporating the modifications and safeguards described below, is environmentally sound for indefinite storage of PCB-contaminated sediments. The storage of contaminated sediments at the proposed containment site will not have significant long-term adverse environmental impacts to the surrounding communities. 3. The proposed dredging operation, incorporating the modifications and safeguards described below, will not have significant short- or long term adverse effects on the surrounding community, downstream water supplies or the ecology of the Hudson River. 4. Removal and in-river containment of substantial quantities of PCB-laden sediments should demonstrate an improvement of the rate of recovery of the Hudson River. 5. Removal and in-river containment of PCBs from the upper Hudson River will also reduce the risk of: - contaminating downriver water supplies caused by high flow conditions - public health threata due to excessive volatilization from the river bank areas - public health threats due to the consumption of contaminated fish - the necessity to close*the Hudson River fishery due to high flows after projected reopening - permanent closure of the striped bass fishery - conducting environmentally unsound maintenance dredging and upland dispoaal of contaminated sediment from the upper Hudson River and estuary - closing navigable waterways both in the upper and lower Hudson River due to the inability to provide adequate upland containment of containment dredge spoil - endangering aquatic species, in particular the shortnosed sturgeon. 2-46 HONS 009847 6. Removal and in-river containment of PCBs from the upper Hudson River is not expected to significantly reduce PCB sediment concentrations in the New York Harbor. 7. As presently proposed by NYSDEC, PCB volatilization caused by the discharge of contaminated dredged sediment into the containment site could exceed the New York State Department of Health (NYSDOH) recom mended maximum allowable 24-hour average ambient air PCB 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 meaaurea presented below, the i ug/cu m ambient air guideline should not be exceeded. 3. MODIFICATIONS The modifications to the original project, as well as to the reduced-scale project referenced above, include changes in the design, operational standards, contingencies, tnd 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, operation 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 project ere not sufficient to be used for these purposes. These current funds are to be used only for dredging, site construction and closure, and a monitoring program for only the duration of the project operations. Although there are a substantial number of modifications and additions to the original full-scale and 2-47 HONS 009843 reduced-scale project*, most arc directed toward long-tern element* subsequent to containment 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 fessible 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 Sagandaga 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-contaminated sediments to protect workers, residents, agricultural resources, and water supplies. Disposal 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 tha disposal operation# to assure the NYSDOH 1 ug/cu m ambient sir guideline is met, as well as the 0.2 ug/g (ppm) standard for crops set by the FDA 3. Develop specific contingency plans for additional treatment of the supernatant from dewatering prior to discharge if permit limits (to be established) are exceeded. Long-Term Storage 1. Development of long-term maintenance and monitoring program# for a minimum of 30 years with periodic program review by EPA and NYSDOH. 2-48 HONS 009849 2. Contingency plans for (a) long-tern leachate collection and treatment, (b) landfill cap maintenance, (c) excessive PCB volatilization or methane generation, and (d) alternate water supply should monitoring indicate failure of containment site. 3. The 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. A. Provision for specific funding mechanisms by NYSDEC to assure imple mentation of long-term contingency plans, operation, maintenance, and monitoring. 5. Redesign of che 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 NYSDOT 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 Che incre mental costs associated with disposal and long-term storage. 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 maintenance program if in-river containment is implemented to determine leaching of PCBa back into the river. 3. Develop a downstream public water supply monitoring program for PCBs and heavy metals to ba 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. 4. CITIZEN INVOLVEMENT It is also recommended 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 2-49 MQNS 009850 if so desired by che respective committees. The committees would serve ss s community focal point for che distribution of project information and data and, at the same time, provide oversight and local and technical liaison between che affected communities and the operational and regulatory agencies, including CPA. The CAC has raised two issues of public concern which should be considered by New York State. 1. NYSDOT 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. NYSDEC 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. 2-50 HQNS 009851 CHAPTER 3 AFFECTED ENVIRONMENT (EXISTING CONDITIONS) This chapter presents descriptions of the natural end man-made environmental resources that may be affected by the alternatives under consideration. 1. EARTH RESOURCES la. Regional Geological Setting Bedrock Geology Geological units in the region are composed of both consolidated and un* consolidated materials. The area is underlain predominantly by shales with minor occurrences of slate and grayvacke. Blue-black to gray clayey shale layers (a few inches to several feet thick) and some sandstone layers (rarely more than 8 cm (3 in] thick) make up the shales. These bedrock formations, as observed in outcrops and borings in the area, dip toward the southeast. In areas of jointing and fracturing, many fractures are tightly sealed with calcium carbonate. However, the remaining open joints and fractures allow the migration of water. Surficial Geology In most places, the bedrock is overlain by unconsolidated gleciel materials and sore recently deposited materials ranging in depth from a few inches at rock outcrops to more than 60 m (200 ft). The identifiable unconsolidated sediments are: (1) glacial till, (2) glacial outwash, (3) ancient lake deposits, (4) recent river deposits, and (3) modern dredge spoils. The glacial deposits are the result of Che Wisconsin Age glacial advancement that eroded and smoothed the bedrock surface during the Pleistocene Epoch. 3-1 HONS 009852 Glacial till deposits, which cover approximately 10 percent of the upper Hudson basin are highly variable assortments of rock materials ranging in size from clay particles to rock fragments and boulders. The till usually occurs as ground moraines of varying thickness. Generally, the till is not stratified but local pocketa of sand, gravel, silt, and clay do occur within the till maaa. Deep till deposits tend to be more compact and dense than shallow depoaita that have been weathered more completely (MPI, 1978a). Glacial outwash deposits consist of sand and gravel sorted by glacial melt water. These deposits are generally younger than, and commonly rest on, till. Valley-fill deposits were formed in lakes or stream channels where spillways were formed by ice or glacial debris. Approximately 25 percent of the upper Hudson River area is overlain by glacial outwash. Outwash deposits occur in most stream valleys tributary to the Hudson River. The thickness of the de posits is influenced by the shape and original bedrock of the valleys. These highly variable sediments are usually stratified, consisting of gravel, coarse through fine sand, and clay. Deltaic deposits are fan-shaped outwash formations that were generated at points where streams laden with large rock debris entered the still waters of proglacial Lake Albany. Deltaic deposits are composed of materials ranging in size from coarse gravel to fine sand and silt (MPI, 1978a). Ancient lake sediments, which occupy up to 60 percent of the upper Hudson area, were deposited on the bottom of proglacial Lake Albany. This lake ex tended from Rensselaer County to Essex County some 10,000 to 15,000 years ago. These deposits were laid down in the quiet water of the glacial lake and were eventually exposed as flat terraces or bottomlands when the lake drained, near the end of the Pleistocene Epoch. Today, the formations are found along the Hudson River as terraces, covering flat to gently rolling valley floors. The lower beds are predominantly fine-grained bluish clays grading to yellowish-red silts (MPI, 1978a). Recent river deposits, known as alluvium and consisting of sediments of various textures deposited along streams, occupy leas than five percent of the upper Hudson area. These deposits are usually located on the floodplains within 790 m (2,600 ft) of the banks of the Hudson River and certain tributaries. HONS 009653 3-2 Canal dredging spoils has been deposited along the Hudson River as a result of human activity within the study area. These deposits are generally coarse grained, consisting of quartz-feldspar sands, cinders, and shale cobbles, mixed with wood fragments ranging from sawdust to pieces several feet long (MPI, 1978a). Seisnic History Seismic events recorded in and around the upper Hudson River Basin have been moderately common, although not excessively damaging. Earthquakes in the area indicate that movements are associated with known or closely related faults. The area is listed in the Zone 2 (moderate damage) seismic risk area. Algermissen and Perkins (1976) estimate that there is approximately e ten percent chance that the bedrock units in the area will undergo horizontel acceleration (shaking) that exceeds nine percent of the force of gravity at least once in a 50-year period. Soils Host of the soils within the upper Hudson River Valley have been formed in mineral material deposited by the Wisconsin Age glacial advancement, the most recent glacier of the Pleistocene Epoch. Some soils, however, have been formed in more recent deposits of alluvium or dredge spoils. * Shallow soils developed in glacial till over bedrock are rare in the area and are usually found on undulating to hilly uplands. Drainage of these soils ranges from moderately well drained to somewhat excessively drained. A denae subsurface soil layer, low in organic matter and slowly permeable, called a fragipan, is often encountered in these soils. Fragipan may seriously impede drainage and result in localized elevation (perching) of the groundwater table. Shallowness of soil to bedrock or a fragipan, as well as numerous rock outcrops, ere the main limitations for farm and nonfarm uses (MPI, 1978a). Soils that have been developed in glacial lake sediments occur quite exten sively on lake plains and valleys within the upper Hudson River Basin. These deep soils, found on slopes ranging from nearly level or depressions! to very 3-3 HONS 009654 teep, are classified as somewhat poorly drained to well drained. The wetness of these clayey and silty deposits increases with depth; water contents as high as 60 to 70 percent have been reported (U.S. Department of Agriculture, Soil Con* servation Service, [USSCSj 1975). These clayey and silty deposits are highly susceptible to frost action and their sticky and plastic character makes them difficult to work when wet. The soils formed on plains, terraces, and glacial outwash deposits in the valleys are deep, and somewhat excessively drained, and moderately coarse tex tured. Many of these soils are underlain by lenses of silt and clay that impede their drainage. Droughtiness and the large number of coarse fragments are the main limitations for farm uses. Soils that have formed in recent alluvium on floodplains are usually deep, medium textured (high in silt and very fine sand), and characterized by drainage classes ranging from very poorly to well drained. These soils are all subject to annual or more frequent periods of overflow, except along the Hudson River where the flow is regulated. The weter tables in these soila fluctuate and are deter mined to a large extent by the water level of adjoining streama. Flooding is the main limiting factor for use of these soils. lb. Containment Site Geology The following is a brief discussion of the bedrock, surficial geology, and soils at the containment site. For more detailed discussions of field investi gations and environmental conditions at the containment site, the reader is referred to MPI (1978b, 1980a, and 1980b). Bedrock Geology The bedrock that underlies the site and outcrops adjacent to the aits is part of the Snake Hill Formation. This rock is a dark gray, fissile (capable of being split along closely spaced parallel planes), unweathered, moderately jointed to broken, calcareous shale. There are a number of springs discharging along the slopes and at the base of the rock outcrop south of the site. Depth to 3-4 HONS 009855 bedrock varies greedy ac Che sice, from jusc below the ground surface in che outheasc and souchwesc corners to approximately 23 m (75 ft) below ground surface in the northeast corner (MPI, 1980a). Surficial Geology The unconsolidated material overlying Che bedrock ac che containment sice consists of fine-grained sediments deposited in glacial Lake Coveville. The claya are typically varved (layered) and were deposited during the retreat of che Wisconsin Age glacier, approximately 13,000 years ago. The varved clay begins beCveen 89 to 167 cm (35 to 66 in) from the ground surface and excends to a depch of 10 m (30 ft). The vsrves are a result of seasonal sedimentation and consist of alternating laminae (thin layers) of dark grayish-brown clay (from 0.5 to 3.8 cm [0.2 to 1.5 in] thick) and silty material (leas than 0.2 to 2.5 cm [0.1 to 1.0 in] thick). Occasionally, lenses of very fine send ere found between the clay layers, but they do not appear to be con tinuous. Deposits of calcium carbonate are identifiable 61 to 91 cm (24 to 36 in) below the surface. The cerbonace usually occurs in discontinuous vertical scams, but at a few locationa pockets of carbonate exist that are 8 to 10 cm (3 to 4 in) thick. The pockets of carbonate (lime) are generally found 1.2 to 1.5 m (4 to 5 ft) below the surface and contain irregularly shaped carbonate nodules that are 0.63 to 2.5 cm (0.25 to 1.0 in) in diameter. The major clay minerals present are illite, montmorillonite, chlorite, and venniculite with some trace kaolinite and smectite (MPI, 1980a). Analysis performed on the borings by the engineering firm of Muser, Rut ledge, Johnston, and Deaimora (MRJD) (Richards, MRJD, April 22, 1980) indicates chat the unconsolidated material overlying the bedrock ia variable in thickness. In the northern and central parts of the containment site, the thickness of che clay material ranges from 10 to 23 m (35 to 75 ft). Along the southern portion of the site, bedrock is closer to the surface and the thickness of the clay varies from 0.6 to 12 m (2 to 40 ft). In the south central portion of the sice, the bedrock outcrops and the overlying clay thins significantly. The actual containment facility will not extend to this portion of che site (MPI, 1980b). 3-5 MQNS 009856 The clay material at the site may be divided into two basic types. The upper layer, identified by MRJD as stratum C^, is basically a stiff, brown to graybrovn clay, varved with trace layers and pockets of silt to clayey silt with occssional fine sand seams. The natursl water content for this material ranges from 29 to 38 percent of dry weight. Below this stratum is a softer clayey material with an average water content that varies between 33 and percent of dry weight. Because material has a higher water content and is softer, material is more suitable for use in the construction of containment dikes and the clay cover (MPI, 1980a). Laboratory and field tests were performed on the unconsolidated material to determine the engineering, physical, and hydrologic characteristics of the material. Tests of the permeability of the lake bed material indicate a range from 2.5 x 10 ^ to 5.88 x 10 ^ cm/sec (8.2 x 10 ^ to 1.92 x 10 ^ ft/sec). New York State regulations on hazardous waste deposits require a clay seal at the site having a hydraulic conductivity of not greater than 1 x 10 ^ cm/sec (3.3 x 10 ^ ft/sec) and PA requires an overall in-place permeability of not greater than 1 x 10 -7 cm/sec (3.3 x 10-9 ft/sec). Physical analysis of the varved clay indicates that 90 percent of the particle sizes are finer than No. 200 sieve size. An Atterberg Limit Test run on both pure clay samples and clay varved with silt indicated that the Liquid Limit is greater than 30 and a Plastic Index greater than 15 (MFI, 1980a). Soils The predominant soil type found in approximately 53 percent of the contain ment site is the Kingsbury silty clay. Other similar soils found at the site are the Covington silty clay loam and the Vergennes silty clay loam, which account for about 20 and 21 percent of the area, respectively. A minor portion of the aite (6 percent) is Nassau shaly silt loam, a shallow, medium-textured soil that formed in glacial deposits. Properties of these soils ere presented in Table 3-1. The Kingsbury soil occupies the nearly level portions of the site, while the Vergennes soils have formed on the more sloping sections. Covington soils are found along drainways and at the base of slopes (USSCS, 1975). 3-6 MONS 009857 Table 3-1 Characteristics of Soils within the Containment Site Soil Series Area Occupied Percent of Total De pth to Bedrock.* Seasonal High Water Table (> ao (m) (ft) Drainage Land Use Capability Agricultural Suitability Kingsbury silty clay Vergennes silty clay loam Covington silty clay loam Nassau shaly silt loam Severe limita Soils have Somewhat tions due severe limita 53 >1.1 >3.5 0-0.& 0-2.0 poorly to to periodic tions that re poorly standing water duce choice of plants Very severe Majority have Moderately limitations severe limita 21 >1.1 >3.5 0-0.6 0-2.0 well due to risk tions that re of erosion duce choice of plants Very severe Soils have se Somewhat limitations vere limita 20 >1.1 >3.5 0-0.6 0-2.0 poorly to due to per tions that re poorly iodic stand duce choice of ing water plants Somewhat ex Very severe Soils have se cessively limitations vere limita 6 0.3- 1-3.5 0.5- 1.5 well to well due to risk tions that re l.l 1.1 3.5 of erosion duce choice of plants Note: These depths are for typical soils. It nay vary significantly depending on the location. Source: MPI, 1980a. HONS 0 0 9 8 5 8 The agricultural potential for Site 10 is limited. The majority of soils fell within agricultural suitability Classes III and IV. These are defined as having severe agricultural limitations, primarily due to excessive wetness and slow permeability, that reduce the choice of plants and/or require special conservation practices. Kingsbury soils are estimated to yield 27 to 36 metric tons (t)/ha (12 to 16 short tons [tn)/a) per year of corn for silage, or 5.6 to 9.0 t/ha (2.5 to 4.0 tn/a) per year of forage mixture. Vergennes soils are estimated to yield 27 to 40 t/ha (12 to 18 tn/a) per year of corn for silage, 4,350 to 6,960 liters (l)/ha (50 to 80 bushels (bu]/a) per year of corn for grain, or 5.6 to 11.2 t/ha (2.5 to 5.0 cn/a) per year of forage mixture. Coving** ton soils are estimated to yield 4.5 to 7.8 t/ha (2.0 to 3.5 tn/a) per year of forage mixture. Nassau soils are estimated to yield 4.5 to 6.7 t/he (2.0 to 3.0 tn/a) per year of forage mixture (Newton, March 28, 1981). Therefore, on the proposed containment site the potential yields are estimated to be 20 to 27 t/ha (9 to 12 tn/a) per year of corn for silage, 870 to 1,390 1/ha (10 to 16 bu/a) per year) of corn for grAin, or 5.4 to 9.0 t/ha (2.4 to 4.0 tn/a) of forage mixture. At present the proposed containment site is not active farmland. The current property owner is neither a farmer nor a resident of the area (Newton, March 28, 1981). lc. River Bed Materials in Upper Hudson River The sedimentary deposits within the upper Hudson River in the aree between Glens Falls and Troy are characterized by geographically and temporally inter mittent distributions, caused by varying hydraulic regimes and sediment sources. In areas of moderate velocity, bottom materials consist primarily of sands and gravels in combination with concentrations of coarse-grained organic debris including wood chips, sawdust, and lath. Within low velocity backwater areas, sediments become progressively finer as the coarser materials are replaced by silts and clays (LMS, 1978). Sediments with a grain size ranging from medium to very fine sand can be eroded at the lowest velocities and, therefore, tend eo accumulate in the more protected areas. Both clays and gravel require much higher velocities to be eroded. The clays sre held in place by cohesive forces, while the gravel is held in place by its weight (Vanoni, 1977). 3-8 MGNS 009859 Numerous sampling programs of Che upper Hudson River bed material have been carried out as pare of this study. The most extensive program was carried out by Normandeau Associates from 1976 to 1977. Cores of river bed deposits were obtained from Lock 7 at Che Troy Dam and were analyzed for PCB concentrations, sediment grain-size distribution, sediment/PCB relationships, and distribution of PCBs within the river channel. Detailed discussions of the results of this and other river surveys can be found in Tofflemire (1976). Tofflenire and others (1979), Tofflemire and Quinn (1979), and MPI (1978a, 1980c). The following is a brief summary of the findings. The majority of the Thompaon Island Pool samples had average grain sizes that ranged from fine to very fine sand. Overall, the median grain aize of the hot spots fell within the very fine sand range. Approximately 21 percent of the samples had average grain sizes greater than 2 millimeters (on) (0.08 in), and * large portion of the gravel-sized material consisted of wood chips. Samples obtained along Che length of the river were extremely variable, but indications are that finer textured materials were more common closer to the shoreline and in slack water deposits. In general, the Thompson Island Pool deposits had a coarser texture then those found in the downstream pools. Average organic and clay contents of bed deposits are presented in Table 3-2. Organic materials within the bed deposits ranged from colloidal size humus to wood fragments several feet in length. Organic matcer has been shown to adsorb PCSs from waters, thereby largely affecting PCB concentration and distri bution within the bed deposits. Total volatile solids within the deposits ranged from 0.6 to 92.7 percent by weight in the Thompson Island Pool and from 0 to 93.1 percent by weight south of the pool. The average content of volatiles for the total study reach was approxi mately 7.0 percent by weight. The high percentages of volatile solids within the deposits are due to wood fragments. Most of the volatile solida within the materiel were associated with the grevel-sized fraction (MPI. 1978a). PCB values tend to be high in coarse sand-sized particles, low in sand-sized particles, and high again in the silt- and clav-sized particles. The coarse HONS 009660 3-9 Table 3-2 Bed Deposit Properties Pool Thompson I Lock 5 Lock 4 Lock 3 Lock 2 Lock 1 Percent Clay 5.82 7.53 4.01 7.27 3.96 0.74 Percent Volatile Solids (by weight) 7.5 11.8 4.36 10.07 3.76 2.23 Total Reach 5.34 6.96 Source: MPI, 1978a. Number of Samples 211 118 293 36 9 4 671 3-10 MQNS 009861 fraction contained a significant higher percentage of volatile solids (largely wood chips), thus accounting for the high PCB content. PCBs also adsorb to clays and fine silts (Tofflemire and others, 1979; Tofflemire and Quinn, 1979). The greatest quantities of PCBs are located immediately downstream from the former discharge points in the remnant deposits and in the Thompson Island Pool. Estimates of PCBs in the remnant deposits range from 29,000 kg (64,000 lb) (Tofflemire and others, 1979) to 63,500 kg (140,000 lb) (MPI, 1978a), and in the Thompson Island Pool from 53,500 kg (118,000 lb) to 60,600 kg (133,700 lb) (MPI, 1978a). The entire upper Hudson River, including the remnant deposits, is believed to contain between 148,800 to 178,700 kg (328,200 to 394,000 lb) of PCBs. The average level of PCBs exceeds 50 ug/g (ppm) in the Thompson Island Pool and Lock 5 pool, but is lower in the remaining pools (MPI, 1978a). Concen trations genarslly decrease with distance downstream, although the Lock 4 pool levels are low in comparison with those of the Lock 2 and 3 pools. PCB levels in the center of the river and along the eroding bank are typi cally in the range of 5 to 20 ug/g, (ppm) while levels along the depositional shore may range from 50 to 1,000 ug/g (ppm) in fine grained sediments. Stati stical analyses in the Thompson Island Pool and Lock 5 and 6 pools showed sign ificantly higher PCB levels along near-shore areas of the river, in comparison to ehe middle third of the river. The differences among the Lock 1, 2, and Troy Dam pools were not significant (Tofflemire and Quinn, 1979). NYSDEC haa prepared a summary tabulation of average PCB concentration with depth of sediment core (Tofflemire and Quinn, 1979). The cores were taken principally in the soft near-shore sediments. Cores registering less than 6 ug/g (ppm) PCBa were not included. Above Lock 7 and in the Thompson Island Pool, peak PCB levels of approximately 130 ug/g (ppm) were generally found at depths of 30 to 45 cm (12 to 18 in). Further downriver from the Lock 6 pool to the Troy Dam, the PCB peak typically occurred at between 8 to 30 cm (3 and 12 in) deep. The peak PCB strata averaged about 150 ug/g (ppm) in the Lock 5 and 6 pools, and decreased to approximately 50 ug/g (ppm) in the remaining downstream pools (Tofflemire and Quinn, 1979). 3-11 HONS 009862 Sediment samples taken in a variety of locations in the upper Hudson River how elevated levels of chromium, lead, and zinc in addition to PCB. Sediments from behind the original Fort Edward Dam that were examined in 1970 contained lead and zinc in very high levels, up to 3,630 and 2,950 ug/g (ppm), respec tively (Clarkson and Clough, 1970). Limited samples taken in the remnant de posits following the removal of the dam in 1973 showed very high levels of lead, up to 5,600 ug/g (ppm) (MPI, 1978b). Elevated sediment levels of chromium, leed, and zinc were found at the Thompson Island Pool (Tofflemire, 1976) and at the confluence with the Moses Kill (GE, 1977). Representative grab samples taken by NYSDOH throughout the upper Hudson River showed the following mean values: chromium, 705 ug/g (ppm); lead, 387 ug/g (ppm); and zinc, 217 ug/g (ppm) (Tofflemire and Quinn, 1979). Statistical analysis indicates that of the metals sanpled, the distribution of lead most closely approximates the distribution of PCBs. (The correlation coefficient of log lead versus log PCBs is 0.609.) This observation is based on grab samples taken to depeh of six inches, which are, therefore, likely to consist of recently deposited sediments. The correlation suggests that lead levals should be closely monitored during any remedial dredging (MPI, 1980d). Id. River Bed Materials in Lower Hudson River . The estuarine portion of the river below the Federal Dam is estimated to contain 75,700 kg (167,000 lb) of PCBs (Bopp, 1979; Bopp and others, 1981). The following depositional areas in the lower Hudson River have higher concen trations of PCBs: Albany turning basins (River Mile 109.5), Kingston area (River Mile 85 to 93), Haverstraw Bay and the Tappan Zee, New York Harbor, and other coves and bays. Among these areas, Sew York Harbor has the greatest mass of PCBs, 23,100 kg (51,000 lb), at an average concentration of 3 ug/g (ppm) (MPI, 1980d). Bopp (1979) estimates that 70 to 75 percent of the PCBs in New York Harbor originated from discharges to the upper Hudson River. 2. WATER RESOURCES 2a. Surface Water Hudson River Basin The Hudson River Basin covers 34,615 square kilometers (sq km) (13,365 3-12 HONS 009863 square miles [sq mil), 27 percenc of New York State. From the Hudson-Sacandaga River junction south to Fort Edward, there is a series of seven dams and three natural waterfalls that are used to generate hydroelectric power. From south of Fort Edward to the Federal Dam at Troy, the Hudson River is regulated by a series of eight dams. In addition to these dams, there are seven locks that are part of the Champlain Canal System. The Hudson River from Albany to New York Harbor is a tidal estuary (MPI, 1980d). The drainage area of the Hudson River varies from 7,299 sq km (2,818 sq mi) at Fort Edward to 20,953 sq km (8,090 sq mi) at the Federal Dam at Troy. To maintain navigation and power generation, flows are regulated to a minimum of 85 cu a/sec (3,000 cfs). The minimum depth of 3.6 m (12 ft) is maintained for navigation. Several reservoirs above Glens Falls affect flow levels in the upper Hudson River. The Sacandaga Reservoir is a 940 million cu m (247,650 million gal) impoundment on the Sacandaga River, which joins the Hudson River at Hadley. Flows from the reservoir are regulated during low flow to maintain navigation, water quality, and powar generation downstream. Flows from tha reservoir are regulated to control flooding during high flows. Water is released from this reservoir to maintain a minimum of 85 cu m/s (3,000 cfs) at Spier Fails (MPI, 1980d). Ocher reservoirs that affect flows in the upper Hudson River are Indian Lake, Piseco Lake, Spier Falls Reservoir, and Sherman Island Reservoir. Low flows are generally observed between July and October of each year and have been recorded at 14 cu m/sec (500 cfs). April and May are annual high flow periods when rates over 280 cu m/sec (10,000 cfs) are common, and a flow of 1,113 cu m/sec (39,319 cfs) was recorded on April 2, 1976, during the 100-year flood. Water Quality New York State water quality classifications and standards are listed in Table E-l (Appendix E). Classifications for the upper Hudson River vary from "A" to "0" and are based on the intended "best use" for these waters. Classification of the river, as reported by MPI (1978a), is as follows: 3-13 MONS 009864 From Lock 7 downstream to the mouth of the Snook Kill 3.7 km (2.3 mi) the waters are classified 'E>': suitable for secondary contact recreation but not for the propagation of fish. From the Snook Kill to Fort Miller 9.0 km (5.6 mi) the classification changes to 'C': intended as suitable for fishing and other uses except water supply and contact recreation. The classification reverts to '0' downstream to the mouth of the Batten Kill (6.1 km) (3.0 mi), then back to 'B' along the 25.7-km-(16-i) section south to Lock 3. 'B' waters are intended as suitable for contact re creation and other uses except water supply. The classification is reduced to 'D' betwen Locks 2 and 3, but is upgraded to 'A' below Lock 2, a classification that does not necessarily reflect improved water quality as much as the fact that this section is used as a public water supply for the Village of Waterford. Water quality data for the Hudson River are collected by NYSDEC, USCS, and NYSDOH. These data are presented in Table E-2 (Appendix E). The data show that, with the exception of mercury, lead, hydrocarbons, and phosphorus, all parameters measured meet state and federal standards. The maximum level for lead that is recommended by EPA is 12 ug/l (ppb) in soft waters. Point and Non-Point Sources Glens Falls, Fort Edward, Fort Miller, and Mechanicville discharge munici pal and industrial wastes into the Hudson River, causing adverse effects on weter quality. The water quality downstream from Mechanicville improves because of dilution and the biological and chemical breakdown of pollutants (MPX, 1978a). Non-point source (NPS) runoff results primarily from agriculture and can cause increased nutrient levels, turbidity, and erosion. Levels of NPS have not been quantified (MPI, 1978b). 2b. Croundwater Regional Groundwater Two main types of groundwater aquifiera occur in the study area: Ordovicianaged consolidated rocks, and Pleistocene-aged unconsolidated sediments. The consolidated rocks generally have low effective primary porosities. However, in many areas, the presence of joints, fractures, and fault zones has significantly increased the permeability of formations. Yields reported for 192 wells drewing 3-14 HONS 009865 from Che shale aquifer in Washington and Saratoga Counties ranged from 2.0 to 300 liters per minute (lpm) (0.5 to SO gallons per minute [gpm}) and averaged about 34 1pm (9 gpm). Water from shale wells is generally hard and may contain hydrogen sulfide (MPI, 1978a). The unconsolidated deposits yield water of varying quality and at differing rates. Because of its low porosity, glacial till yields water very slowly. The estimated average yield of these deposits ia from 4 to 8 1pm (1 to 2 gpm). The more productive wells derive water largely from thin sand lenses in the till. Glacial outwash deposits have high permeabilities. These stratified sands and gravels have average yields of 19 to 38 1pm (S to 10 gpm). Deltas are the most productive water-bearing glacial outwash formations. Lacustrine deposits of clay and silt yield water very slowly and seldom in usable quantities. The alluvial deposits found in the study area are not coarse enough or thick enough to be important as sources of groundwater. Containment Site Groundwater It is difficult to define a true water table at the containment site because of the variable nature of the lake bed sediments and the extremely low penaeability of the clays. The slowly permeable clays retard groundwater flow to the point that test pits dug through the silty layers to depths between 1.6 and 2.6 o (5 and 8 ft) accumulated water so slowly that a stable level could not be determined (MPI, 1980a). Water levels were monitored in five piezometers in stalled across the site and, after several days of monitoring, stable water levels were reached. These water levels varied from 0.9 to 1.2 n (3.0 to 4.1 ft) below the ground surface. In one boring that penetrated the bedrock, artesian conditions were encountered, but the full height was not measured (MPI, 1980a). The Chin lenaea of fine sand contain pockets of more mobile groundwater. However, the evidence obtained from systematic boring across the site indicates that the extent these lenses is limited and they are not hydraulically connected to each other or to the Hudson or Dead Rivers. Therefore, the groundwater is immobilized within these lenses end, if contaminated, would remain in the same location (MPI, 1980b). The existence of e water table less than 3 m (10 ft) from the bottom 3-15 MONS 009666 of Che containment fecility would prevent New York State regulatory bodiea from approving the site as a secure landfill facility. A waiver would be required for construction of the facility. The site does not recharge any aquifers in the area. Because of the high clay content of the soils and underlying unconsolidated material, most precipi tation falling on the site flows into the Hudson and Dead Rivers as surface runoff. The presence of a small wet area in the south part of the site also indicates the poor infiltration capacities of these soils. Wells in the area of the containment site are used largely for domestic supplies and are located predominantly along Route 4 near the river. These wells vary from 8 to 58 m (25 to 190 ft) in depth and produce up to 76 1pm (20 gpm) of potable water. The formation used is the Snake Hill Shale and the amount of water produced depends on the extent of interconnecting fractures. The formation is recharged where it outcrops approximately 2.5 km (1.5 mi) to the east of the containment site. It is also recharged to a lesser extent by induced infil trations from the Hudson River. The formation water has a high iron sulfide content and, in some cases, is not potable. 2c. Water Supply A number of communities obtain drinking water from the Hudson River, includ ing the Village of Waterford, the Port Ewen Water District, the Village of Rhinebeck, the City of Poughkeepsie, and the Highland Water District (MPI, 1980d). In addition, several municipalities and numerous private individuals obtain water from wells adjacent to the river. Stillwater, for example, operates four wells and Green Island draws water from infiltration galleries located on an island in the upper Hudson River. Some homes along the Hudson River also use the river as a supplemental water supply for watering lawns and gardens (KPI, I980d). In addition, a water intake exists at Chelsea, which may be used to augment water supplies for New York City during drought conditions. Hudson River water is analyzed by the USGS at five stations on the upper reaches: Glens Falls (above the GE plant), Rogers Island, Schuylerville, Still water, and Waterford (Tofflemire, NYSDEC, 1980). Although the Clens Falla PC8 3-16 HONS 009867 levels ere usually below Che detection limic of 0.1 ug/1 (ppb), chere ere dece for Schuylerville end Scillwecer for the three water years beginning in October, 1976. The average PCB concentrations for these years were: 0.687 ug/l (ppb) in 1977, 0.568 ug/1 (ppb) in 1978, and 0.657 ug/1 (ppb) in 1979. Higher levels have been reported for the 1974 Co 1975 period at Rogers Island 1.5 ug/1 (ppb), and levels as high as 3 ug/l (ppb) were recorded in the Hudson River prior to elimi nation of GE discharges in 1976. PCBs in Hudson River drinking waters can be reduced by 40 to 80 percent through treatment (Cranston, City of Poughkeepsie, August 25, 1977). If standard water treatment measures (alum coagulation, settling, aeration, sand filtration, and chlorination) are used, levels of PCBs in finished water can be reduced frost the present approximate level of 0.65 ug/1 (ppb) to about 0.20 ug/1 (ppb). There was no significant difference in the -amount of PCBs in the water for the three-year period between 1977 and 1979. These levels probably represent back ground levels for residents using the Hudson River, and possibly also wells and infiltration galleries near the river, for drinking water. Residents using this water may assimilate approximately 0.3-1.3 ug/day at an average water consumption rate of 2 lpd (0.5 gpd). Monitoring of Hudson River water at Poughkeepsie and Waterford by the USGS indicated PCB levels below the maximum level of 1.0 ug/1 (ppb) established by NYSDOH and below the 0.16 ug/1 (ppb) level calculated to represent a lifetime cancer risk of one in one million (MPI, 1980d). NYSDEC data indicate that primary and secondary federal and state drinking water standards are presently being met in finished water at the five water supply intakes along the Hudson River (Appendix E). In addition, che 1 ug/l (ppb) short-term exposure standard for PCBs developed by the NYSDOH is also being met. However, it should be noted that during high flow periods, or 10 percent of the time, the 1 ug/1 (ppb) standard for PCBs in finished water may be exceeded at some of the treatment facilities (Figure 2-1). 3. AQUATIC ECOLOGY The lower Hudson River south of the Troy Dam is an estuarine ecosystem. The river's free connection to the ocean, the mixing of ocean salt water with freshwater from the land, and the resulting salinity gradient below Poughkeepsie are the main factors affecting the flora and fauna of the Lower Hudson River. 3-17 MONS 009868 extensive development of the shoreline of New York City and cities to the north, as well as the intense use of the river for navigation and industry, have also substantially affected the ecosystem. The estuarine ecosystem of the lower Hudson River is described in An Atlas of the Biologic Resources of the Hudson Estuary (BTI, 1977). A complete listing of the aquatic flora and fauna of the lower and upper Hudson River is given in Hudson River Fish and Wildlife (NYSDEC and USFWS, 1978). (These reports are on file at the five designated depositories as a supporting document to this draft NEPA EIS.) Above the Troy Dam, the Hudson River ia not influenced by the inflow of ocean waters and is a freshwater river ecosystem with corresponding freshwater flora and fauna. The ecology of much of the upper Hudson River between Troy and Hudson Falls has been substantially altered by industrial utilization. 3a. Flora Aquatic vegetation is abundant in tidal shallows and marshes of the lower Hudson River. In the lover estuary, vegetation tolerant of brackish wsters predominates, and freshwater vegetation exista in up-river areas. Submerged aquatic vegetation in the Hudson River includes pondweed, water celery, and water milfoils. Vegetation in freshwater marshes is comprised of cattails, reeds, purple loosestrife, swamp rosemallov, ferns, spike grass, cordgrass, arrow arum, and pickerel weed. Wooded wetlands exist on portions of the river bank and on islands in the river. A complete description of the vegetation of the lower Hudson River is given by the BTI (1977). Typical freshwater wetland species are described by Rawinski and others (1979). The wetlend and submerged vegetation provides cover and substrate for a wide variety of Crustacea, snails, insects, and other fauna. It is also utilized as food for ducks, geese, other waterfowl, and muskrats. Detrital material derived from the vegetation ia consumed by filter feeders such as zooplankton, benthic invertebrates, and menhaden (BTI, 1977). The Hudson River also contains a diverse phytoplankton community, with marine species dominant in the lower estuary. Diatoms, green algae, dinoflagel- 3-18 HONS 009869 laces, and blue-green algae comprise most of the phytoplankton population (BTI, 1977; Hydroscience, 1979). 3b. Wetlands and PCB Hot Spots In ehe upper Hudson River, 8 of the 40 PCB hot spots that have been identi fied by NYSDEC contain wetlands. A brief description of each is given in Table 3-3. Wetlands are not common in the upper Hudson River; they tend to be located in quiescent, depositional areas behind dams or along the margins of islands and the river bank (MPI, 1980d). Because of this, they also tend to be sices of PCB deposition. These wetlands support extensive marsh vegetation and are locally significant habitats for wildlife, especially nesting and breeding waterfowl (MPI, 1980d). The principal species encountered are black duck, mallard, wood duck, golden eye, scaup, green-winged teal, blue-wingad teal, and merganser (MPI, 1978a). NYSDEC has designated the hot spot wetlands that are particularly valuable as wildlife habitats (Koechlein, NSYDEC, June 5, 1980). Hot spot 33 contains a diverse wetland that is extensively utilized by waterfowl. The wetlands at hot spot 40 and between hot spot 39 end Lock 2 are also especially valuable. These wetlands should be restored following any remedial action involving the hot spots. Tha preliminary results of a study of PCB levels in wetland vegetation are available (Buckley, BTI, February 6, 1981). These results indicate that PCB levels in the roots and rhizomes of the marsh plants Pontederia, Leseria, and burr reed (Sparganiua eurycarpum) are generally comparable to PCB levels in marsh soils. In the hot spot wetlands, PCB levels in plant roots are high because of the high PCB levels in the soil. Plant portions chat are submerged obtain their PCB contant from PCBs in Che water column. Similarly, PCB levels in plant portions extending above the water derive their PCB content from airborne PCB. Evidence indicates that there is little upward translocation of PCB from roots to leaves in these marsh plants (Buckley, BTI, February 6, 1981). If this is the case, PCB uptake from the soil by these three plant species may not be a signifi cant pathway for release of the contaminant from hot spot deposits. 3-19 HONS 009870 Table 3-3 Hot Spots and Wetlands Hoc Spot Mean PCB Concentration ug/g (ppm) Contaminated Vo 1 ume cu m (cu yd) Comments 1-7 8 9-12 13 14 15-17 18 19,20 21-24 25 26,27 39-81 99 28-78 89 279 103-380 94 83-249 75-143 100 47-53 98,150 (128,350) No wetlands. 82,850 (108,350) Shallow water on east side of islands includes limited wetlands. Area judged not to present major conflict. Should additional sampling indicate localized, less contaminated areas, these should remain undisturbed. Many overhanging and fallen trees and shallowness will present some hindrance to dredging. 23,400 (30,600) Ho wetlands. 1,550 (2,050) Southern limit of hot spot is at access road berm, major marsh lies to the south. Ho conflict with wetlands. 55,150 (72,150) Ho emergent, some floating and submerged species. Not a wetland. 46,200 (60,450) Ho wetlands. 11,450 (14,950) Diverse 9 m (30 ft) wide bend of marshland present. Conflict exists. 5,950 (7,750) No significant wetlands. 10,650 (13,950) Ho significant wetlands. 10,650 (13,900) Wetland is present. Southern portion of Galusha Island, no conflict. Northern portion contains diverse marsh comaunity and provides valuable waterfowl habitat. Significant conflict. 7,050 (9,200) Ho significant wetlands. 3-20 HONS 009871 Table 3-3 (Continued) Hot Spot Mean PCB Concentration ug/g (ppm) Contaminated Volume cu m (cu yd) Comments 28 29-34 35 36 37 38 39 40 109 51-516 105 51 116 501 161 62 36,350 (47,550) A broad expanse of emergent sedge, pickerel weed, rushes, rice cut grass; offers excellent duck brood habitat. Significant conflict exists, 49,450 (67,700) No wetlands. 8,700 (11,350) Valuable wetland used by waterfowl, herons, other shore birds. Diverse mixture of vegetation types. Distribution of PCB in wetland should be verified. Significant conflict exists. 42,750 (55,900) No wetlands. 43,900 (57,400) Large area of water lilies and water chestnut, used by diving ducks during migration. No major conflict. 11,300 (14,750) No wetlands. 10,050 (13,150) 5 ha (13 a) wetland below hot spot, probably no conflict exists. Sampling is meager, marsh discontinuous. Additional sampling needed. 26,300 (34,400) Valuable diverse wetland communi ties, conflict exists. Recent sampling indicates the area may not be "hot." Note: 1. Assumed value, no samples in this area at this time. Source: a. MPI, 198Qd. 3-21 HONS 009872 Water celery (Vallisneria americana Michx.), a submerged aquatic plant sampled from the wetland at hot spot 28, contained high levels of PCB in plant roots and tops. PCB Levels in plant tops, roots, and river sediments were 18.94, 51.8, and 41.1 ug/g (ppm), respectively (Buckley, BTI, February 6, 1981). PCBa incorporated into the plant can enter Che ecosystem because the plant may serve as food for aquatic birds, especially ducks and geese. Additional PCBa would be absorbed by the organic detritus that is produced when the leaves die, break off, and start to decompose. Upon complete decomposition of the plant parts, the PCBs would be released again into the sediments and water column. A small portion of the detricus would enter the food chain (Bucklay, BTI, March 12, 1981). Loss of PCBs from wetland hot spots may occur from volatilization from marsh soils. However, these hot 9pots also contain large amounts of organic materials, which tend to adsorb PCB and inhibit the release of the contaminant to the atmosphere (MPI, 1980d). Scouring of wetlands during periods of high river flow can cause resus pension of PCB-laden sediments and their release to the river system. Wetlands tend to be less subject to scouring than other river areas because the vegetative cover tends to hold sediments in place (MPI, 1980d). Ice Chat forms on the river during the winter months may also be an important mechanism for release of PCB-contaminated sediments from wetlands. Field studies along the St. Lawrence River have indicated that mats of wetland sediment thet are frozen to the underside of ice can be carried away when water levels riae during the spring thaw. In addition, ice floes can scour wetlands and abrade river banks as ice is moved downstream during the spring melt (Marshall, February 26, 1981). The degree to which ice scouring of wetlands occurs on the Hudson River is not known. The effect of the high PCB levels on wetland vegetation in the hoc spots is also unknown. There is limited evidence that submerged aquatic plants are sensitive to elevated PCB levels. Photosynthetic activity in the aquatic plant 3-22 HONS 009873 Spirodela oligorrhisa has been. shown to be greatly reduced by PCB concentrations of 5 ug/g (ppm) in the ambient water (Mahanty and Fineran, 1976). 3c. Fauna Zooplankton, including copepods, water fleas, larval snails, and other aollusks, are found throughout the Hudson River but are most abundant in the brackish waters of the lower estuary. Zooplankton are important food sources of certain fish, particularly young striped bass, young white perch, and anchovies (BTI, 1977). Snails are the most abundant mollusks in the Hudson River, but clams and oysters are found in the lower estuary. Crustaceans are represented mainly by copepods and' amphipods. Blue crab (an important recreational species) is found in the lower estuary (BTI, 1977). Turtles, frogs, and other reptiles and amphib ians are present throughout the Hudson River system, especially in wetlands. A large variety of fish inhabit the Hudson River and many are coomercially and recreationally important (Smith, 1977). A list of fish species recorded in the Hudson River, along with brief descriptions of their origins and habitats, is presented in Appendix F. The lover Hudson River serves as a spawning area for several anadramous fish, including striped bass, American shad, and Atlantic sturgeon. The broad shallow areas of Havertraw Bay are especially productive for spawning and rearing. The lower Hudson River is the second most important propagation area for striped bass on the east coast. Hudson River striped bass comprise a significant portion of the striped bass fishery on the east coast, which generally has a commercial and recreational value of $20,000,000 per year (MFI, 1980d). Other commercially valuable fish chat inhabit the lover Hudson River in their juvenile stages include bluefish, weakfish, and winter flounder. Bay anchovies are abundant in brackish water, and the species is a major food aource for larger fish (BTI, 1977). The shortnose sturgeon, a species that is on the federal list of rare and endangered species, also inhabits the lower Hudson River. The species will be discussed in section 5 of this chapter. 3-23 HONS 009874 Freshwater fishes thac inhabit the Hudson River include ahiners, goldfish, carp, white sucker, brown bullhead, white catfish, white perch, yellow perch, blue gill, pumpkinseed, black crappie, darters, walleye, chain pickerel, northern pike, largemouth bass, and smallmouth bass. The American eel is abundant throughout much of the Hudson River (BTI, 1977; Smith, 1977). Additional information on the aquatic ecosystem of the upper Hudson River is given by MPI (1978a). 3d. Hudson River Fishery In 1978, much of the Hudson River fishery was closed by NYSDEC because many fish were found to have PCB levels that exceeded the FDA temporary tolerance level of 3 ug/g (ppm). The NYSDEC regulations that have been enacted are: Title 6 of the Official Compilation of Codes, Rules and Regulations of the State of New York. Section 12.19 Regulations for the taking of fish and American eel in the Hudson River and their sale or offer for sale: (a) All fishing and taking of American eel is prohibited in the Hudson River, and its tributary waters upstream from the River to the first falls or barrier impassable by fish, from Fort Edward downstream to the Troy Dam. (b) In the Hudson River, and its tributary waters upstream from the river to the first falls or barrier impassable by fish, from the Troy Dam downstream to the mouth of the river at the Battery, New York City, until November 30, 1981, no person shall: (1) Take or possess American eel. (2) Fish commercially except for Atlantic sturgeon greater than four feet in length, goldfish and American shad. For the purposes of this subdivision, commercial fishing shall include, but noc be limited to, the possession, setting, tending, operation and maintenance of nets or other devices for which a license is required pursuant to Section 11-1503 of the Fish snd Wildlife Law and the sale, offering for sale or possession of fish taken in any of the foregoing nets or devices. (3) When commercial fishing, take or possess striped bass, or fail to immediately return striped bass to the water. (4) Sec gill necs from December 1 through March 14. 3-24 MQN5 009875 (c) The sale, or offer or exposure for sale, of any American eel or any fish, except for Atlantic sturgeon greater than four (4) feet in length, goldfish and American shad, taken in the Hudson River, or its tributary waters upstream from the River to the first falls or barrier impassable by fish, from Fort Edward downstream to the mouth of the River at the Battery, New York City, is prohibited. In 1971, NYSDEC also issued an adviaory against eating more than 230 g (0.5 lb) of fish per week from any New York State waters because of mercury contamination. This advisory was subsequently extended because of PCBs, and it remains in effect today (Sloan, NYSDEC, March 10, 1981). Despite the regulations and advisory, illegal fishing, especially sport and subsistence fishing, and consumption of contaminated Hudson River fish continues (MPI, 1980d). Illegal commercial fishing of striped bass occurs in the lower Hudson River because the fish has a relatively high market value. NYSDEC en forcement officials have intercepted sizeable quantities of Hudson striped bass ready for shipment to markets in New York City (Sloan, NYSDEC, March 10, 1981; Blumenthsl, New York Times, April 3, 1981). PCB Levels in Fish When widescale testing for PCBs in fish began in 1977, it was found that PCB contamination was extensive (MPI, 1980d). Uptake of PCBs by fish probably occurs primarily by diffusion of contaminated water through gills, skin, and other tissues. PCBs accumulate in fatty tissues and can be biomagnified through the food chain. Possible biological pathways of PCB movement in Che environment have been discussed (O'Connors and others, 1978; Hydroscience, 1979; Armstrong and Sloan, 1980; MPI, 1980d). PCB levels in Hudson River fish were found to vary greatly according to species. Studies done in 1978 by NYSDEC revealed that 93 percent of all fillets from striped bass (a large predatory species) contained concentrations of PCBs over 5 ug/g (ppm), with median and mean concentrations of 10 and 18 ug/g (ppm), respectively. PCB levels in fish that are full-time residents of the Hudson 3-25 HONS 009876 River, such as the largemouth bass, were also very high. Resident fish such as els, catfish, goldfish, and carp were found to have especially high PCB levels primarily because these species have high fat content. Minnows and anadramous shad and herring had low PCB levels, generally much less than 5 ug/g (ppm). The blue crab had low PCB levels (around 0.5 ug/g (ppm]) in its muscle tissue, but Che hepatapancreas had considerably higher levels (over 5 ug/g [ppm]) (Armstrong and Sloan, 1980). Analysis of fish sampled since 1977 has shown a substantial drop in PCB levels in many species. PCB levels in American shad caught at Poughkeepsie, for example, decreased by 40 percent from 1977 to 1978, and by 50 percent from 1978 to 1979 (Armstrong and Sloan, 1980; MPI, 1980d). The 1980 data also indicate a decline in PCB levels in striped bass. The trend in striped bass has not been as apparent because the striped base population in the Hudson River is comprised of fish that are full-time residents of the river and fish chat move into the river temporarily to spawn. The two groups have different degrees of PCB accumulation (Armstrong and Sloan. 1980; Sloan, NYSDEC, March 10, 1981). Various factors may have contributed to the initally high PCB levels found when extensive testing began in 1977 and the decline since then; In 1974, the Fort Edvard Dam was removed, releasing PCBs to downstream areas and creating high background PCB levels. In 1976, a significant flood occurred, resuspending PCB-laden sediments and making the contaminant more accessible to uptake by fish. In 1977, active direct discharge of PCBs ended. From 1977 to 1979, flows in the Hudson River were relatively low and no major floods occurred, causing minimal release of PCBs from sediments. The principal forms of PCBs discharged by GE into the Hudson River end incorporated into fish flesh were Aroclor 1242 and Aroclor 1016, which are lower chlorinated aroclors compared to Aroclor 1254. Lover chlori nated eroclors may be less stable and subject to slightly greater degra dation in the environment (Armstrong and Sloan, 1980; MPI, I980d). 1980 Fisheries Data NYSDEC continued its monitoring of PCB levels in Hudson River fish through I960. These data indicate that Che decline in PCB levels is continuing primarily 3-26 HONS 009877 because levels of Aroclor 1016 are declining. Levels of Aroclor 1254, however, are declining only slowly, if at all, in Hudson River fish. Sampling in 1981 should clarify this point (Sloan, NYSDEC, March 10, 1981). The PCB dace collected by NYSDEC in 1979 and 1980 are given in Appendix G. For ten 9pecies, 1980 PCB levels were compared with levels found in the sane species since 1977, as shown in Table 3-4. Only levels in fish sampled from the sane river location were compared. Ho account was made for size or lipid content of the fish in the comparison. For the five species sampled from the lower Hudson River, PCB levels were lower in 1980. Levels in largemouth bass, white perch, yellow perch, and American eel have declined substantially in the paat seven years. The mean PCB level in American shad was approximately 1.5 ug/g (ppm) in 1980, slightly lower than the level for the previous year. For largemouth bass, yellow perch, brown bullhead, and goldfish sampled from the upper Hudson River at Stillwater, PCB levels were substantially lower in 1980 than in 1977. For the two species for which data are available (brown bullhead and pumpkinseed), there was no significanc difference between PCB levels in 1979 end 1980. Data on the moat important commercial and recreational species of the regions, the striped bass, were not included in the comparison because possible sample bias has made data suspect. Data for striped bass caught near the Tappan zee Bridge are given in Table 3-5. PCB levels in striped bass have declined, but the magnitude of the decline remains unconfirmed because of the unreli ability of the data (Sloan, NYSDEC, March 10, 1981). Of the ten species from the lower Hudson River represented in the 1980 date, four still have mean PCB levels above the FDA tolerance level of 5 ug/g (ppm); these are white perch, eel, walleye, and striped bass. The highest PCB level recorded in the 1980 data for the lover Hudson River was 52.70 ug/g (ppm) for an cel from the vicinity of the Verrazano Narrows Bridge. For the five species 3-27 HONS 009878 Table 3-4 Means and Ranges of PCB Levels in Hudson River Fish A. Lower Hudson River American Shad Poughkeepsie American Shad Tappan Zee Bridge Heir 1977 1978 1979 1980 No. S amp 1ed 33 87 N 29 Total PCB (PPm) 3.77 2.25 N 1.42 Range Min Max (ppm) (ppm) 1.11 0.30 N 0,63 11.45 6.73 N 3.87 No. Sampled 19 77 15 30 Total PCB (ppm) 2.40 2.16 <1.37 <1.55 Range Min Max (ppm) (oom) 0.70 0.30 <0.57 <0.52 8.45 9.36 2.51 3.94 tear 1977 1978 1979 1980 No. Sampled N 35 N 6 American Eel Indian Point Total PCB (ppm) Range Min Max (ppm) (ppm) N 81.83 N <8.61 N 1.06 N <1.99 N 263.10 N 22.41 Largemouth Bass Catskil1 No. Sampled N 61 N 30 Total PCB (ppm) N 100.46 N 16.71 Range Min Max (pm) (oca) N 6.18 N 2.60 N 372.00 N 46.17 White Perch Trov Year No. Sampled Total PCB (pp) Range Min Max (ppm) (ppa) 1977 1978 1979 1980 Note: 1. 2. 'N N N 61 100.46 6.18 NNN 30 16.71 2.60 N So dace available. ug/g - ppa N 372.00 N 46.17 No. Sampled 25 N N 10 Yellow Perch Catskill Total PCB (ppm) Range Min Max (ppm) (ppa) 4.91 N N <0.98 0.84 N N <0.30 10.60 N N 4.82 3-28 HONS 009879 B. Upper Hudson River Table 3-4 (Continued) Year 1977 1978 1979 1980 fear Pumpkinseed Stillwater No. Sampled N N 64 75 Total PCB (ppm) N N 19.91 20.12 Range Min Max (ppm) (ppm) N N 15.63 14.80 N N 25.43 29.48 No. Sampled Yellow Perch Stillwater Total PCB (ppm) Range Min Max (Dim) (ppm) Largemouth Bass Stillwater No. Sampled U 17 N 26 Total PCB (ppm) 52.41 158.20 N 10.16 Range Min Max (ppm) (ppm) 6.22 20.53 N 1.67 140.84 305.50 N 66.78 Brown Bullhead Stillwater No. Sampled Total PCB (ppm) Range Min Max (ppm) (ppm) 1977 1978 1979 1980 ' 30 12.23 1.56 42.69 30 109.57 35.46 242.19 NNNN N NN N N NN N 30 <8.97 <0.83 59. 79 <0.84 <0.33 2.15 30 12.34 3.50 30.11 Year 1977 1978 1979 1980 Goldfish StilIwater No. Sampled Total PCB (ppm) 10 382.90 24 216.05 NN 30 72.62 Range Min Max (ppm) (ppm) 736.29 58.00 N 11.47 79.69 658.30 N 267.61 Note: 1. N * No data available. 2. ug/g ppm Source: Hydroscience, 1979; Armstrong and Sloan, 1980; NYSDEC, unpublished data. 3-29 HONS 009880 Table 3-5 PCB Trends for Striped Baas, Hudson River. 1973-80, Tappan Zee Bridge Date 1973a 1975a 1976a No. Fish 22 6 46 Mean Length tin (in ) 654 (26) 666 (26) 543 (21) Total PCB ub/r (ppm) 14.753 11,023 Ratio of Aro 1016 to Aro 1254 NA NA 8.62 0.80 1977a 5 507 (20) 8.01 0.28 1978a 130 549 (22) 10.33 0.88 1979a 1980b 1980b 14 301 302 456 (18) 468 (18) 515 (21) 5.27 5.59 6.37 Notes: 1. 2. 3. 4. Sampled 4-14-80 Sampled 5-8-80 Aroclor 1254 measured only NA Not available. 0.31 NA NA Sources: a. Armstrong and Sloan, 1980. b. NYSDEC, unpublished data. 3-30 HONS 009881 sampled from Che upper Hudson River, all but yellow perch had levels well above 5 ug/g (ppm). The highest levels were found in goldfish, with a mean PCB concen tration of 72.62 ug/g (ppm). Effects of PCBs on Health of Fish The effects of PCBs on the health of natural fish populations are not well understood. Adverse effects may be greatest for reproductive and larval stages, as indicated by limited laboratory evidence. Spawning of fathead minnow, for example, has been shown to be affected significantly by exposure to 1.8 ug/1 (ppb) Aroclor 1254 in the water column (USEPA, 1976a). Despite the high levels of PCBs that have existed in certain fish species, in-river toxicological effects, such as fish kills, have not been confirmed in the Hudson River. According to MP1 (I980d), possible reasons for this are: (1) The effects on particular segments of the aquatic life cycle are not documented. (2) Certain organisma may have developed a resistance to PCBs and other Hudson River pollutants as a result of long-term exposure. Several health effects that may be related to contaminant levels have been observed in the Hudson River (Kuzia, NYSDEC, January 21, 1981). Numerous gold fish collected over a 105-km (65-mi) stretch of the river were found to have extensive skin ulcerations, possibly caused by the bacterium Aeromonas salmonicida. The disease also appears in golden shiners and black bass. Two extensive mortalities of white perch have occurred, but a causative agent was not discovered. A 25 percent incidence of liver tumors reported in Hudson River tomcod may be related to PCB contamination. U.S. Fish and Wildlife Service (USFWS) investigations hsv* determined that striped bass fry and fingerlinga contaminated with PCBs have backbones chat are considerably weaker than thoae of fish from other waters. Through its possible effect on backbone strength, PCBs may reduce the ability of the young bass to compete for food and endure the 3-31 MQNS 009882 stresses of migration and reproduction. The possible relationship between contaminant levels and fin rot in the endangered shortnose sturgeon will be discussed in section 5 of this chapter. Potential Value of Fishery If a full-scale fishery could develop on the Hudson River, it would have substantial regional and local importance. Sheppard (1976) has estimated that the Hudson River has Che potential to produce an annual commercial finfish harvest of 560,000 to 890,000 kg (1,240,000 to 1,960,000 lb) with a value of $261,000 to $426,500 (1976 dollars). Sheppard (1976) has estimated that a recreational fishery in the upper Hudson River could support 100,000 man-days of recrescional fishing, with a corresponding economic value of $1,250,000 (1976 dollars). Sheppard has assigned an annual value of $1,350,000 (1976 dollars) Co the recreational fishery in Che lower Hudson River. 4, TERRESTRIAL ECOSYSTEM Below is t discussion of the terrestrial ecosystem at and around the pro posed containment site (Site 10). Additional information on the terrestrial flora and fauna of che upper Hudson region is given in Hudson River Fish and Wildlife Report (NYSDEC and USFWS, 1978]. (This report is on file at the five designated depositories as s supporting document to this draft NEPA EIS.) 4a. Flora The area of the proposed containment site is mainly agricultural, consisting of planted and abandoned hay fields. Approximately half che site has not been pastured or mowed for four to ten years. The western fields consist mainly of grasses, milkweed, trefoil, three-square sedge, daisies, cow vetch, narrow leaved cattail, and wild strawberries. The eastern portion of Che site contains these species, in addition to buttercups, Sc. John's wort, elm and cherry seedlings, hard hack, and meadow sweet (MPI, 1980a). The northeastern portion of the site has been abandoned long enough to have developed a young stand of slippery elm, aepen and willow. Fence rows are lined with elms, white oak, shagbark hickory, black cherry, ash and grey stemmed dogwood. The largest trees on the site are 3-32 MOWS 009863 willows snd tins, snd stversl are up to approximately 1 m (3 ft) in dimeter (MPI, 1980 d). Parts of the proposed containment site contain vet soils and are considered to be wetlands under the New York State definition. Wetlands present on the site include: A 1.2 ha (3 a) seasonally wet grove of slippery elm Linear wetlands totalling over 5 ha (12.34 a) in area along drainage ditches, with vet meadow species such as rushed, sedges and cattail A 1.2 ha (3 a) marsh at the foot of the shale ridge on the southeast portion of the site, containing a diverse assortment of wetland shrubs, sedges, ferns, rushes and mosses (MPI, 1980d). The soils at the site have serious limitations for agricultural production because they have low permeability and tend to be excessively wet. The rooting depth of crops is usually limited to the upper 23 to 30 cm (10 to 20 in) of soil because of a seasonal high water table and slowly permeable subsoil. Because of the soil conditions, the site is more suited for the production of hay and pasture mixtures that tolerate wetness chan for the production of row crops. The gently sloping areas of Che sice are subject to erosion, and the use of pasture crops controls the loss of surface soil (MPI, 1980s). Lands in the region of the proposed containment sice are agricultural and mainly utilized for production of dairy cattle. Corn, hay, and ocher crops for use as animal feed are also grown in the area* Additional information on the dairy industry of the region is given in section 4d of this chapter. 4b. PCB Levels in Terrestrial Flora Terrestrial plants are known to absorb PCBs from the atmosphere. Background atmospheric PCB levels resulted in detectable PCB concentrations in all the foliage analyzed by Buckley (1980) in Washington and Saratoga counties. Con centrated sources of PCBs, such as PCB dumpsites, increase uptake by foliage in surrounding vegetation within a radius of 300 to 700 m (1,600 to 2,300 ft). PCB levels measured in foliage around PCB dumpsites sre given in Table 3-6 snd Table 3-33 HONS 009604 3-7. At the Fort Miller dumpsite, PCB levels of 58 ug/g (ppm) were found in leaves adjacent to the site, and levels decreased to background levels, below 0.3 ug/g (ppm), approximately 700 m (2,300 ft) distant from the site. Elevated PCB levels also exist around some roadways in the region. The PCBs may have been derived from dredge spoil material chat was used to sand roads in winter. PCB levels also tend to be higher within a 2,000 to 4,000 tn (2,200 to 4,400 yd) wide margin on each side of the upper Hudson River (Buckley, 1980). Levels of PCBs in roots tend to be comparable to levels in soil if the soil is sandy and low in organic matter. PCBs are retained by organic matter and clays, making the contaminant less accessible to uptake by plant roots (Buckley, 1980). If PCB-concaminated leaves fall to the soil and decay, the PCBs tend to volatilise as ehe plant matter decays, rather than accumulate in the soil. However, PCBs in leaves that are ploughed or disked into the soil would remain there for several years at plough depth (Buckley, 1980). There are differences in the degree to which different plant species absorb PCBs. PCB levels derived from background atmospheric sources were found to be 0.03 ug/g (ppm) for alfalfa and 0.29 ug/g (ppm) for golden rod. For root crope, carrots accumulate PCBs from the soil more than sugar beets and radishes. PCBs are accumulated in the outer tissues of carrots and beets so that peeling removes 90 percent of the contaminant. However, PCBs are uniformly distributed in radish (Buckley, 1980). PCB levels in forage crops in Saratoga and Washington Counties ere generally well within the 0.2 ug/g (ppm) limit set by the FDA for PCBs in animal feeds. PCB levels in forage crops grown near PCB sources, such as landfills and roads, have been found to exceed the limit (Buckley, 1980). Additional information of PCB crops of Che region is in section 4d of this chapter. Terrestrial plants are apparently able to tolerate high levels of PCBs in surrounding soils and in their tissues. ^Native plants growing in 10,000 to 30,000 ug/g (ppm) PCBs at the Port Miller dump site show no visible symptoms of 3-34 HONS 009885 Location Fort Miller Dump Site Ceputo Dump Site Bouy 212 Dredge Spoil Site Moresu Dredge Spoil Site (Old Moreeu Site) Table 3-6 Increaeee in Foliage PCB Levels Maximum Distance of Foliage from Original PCB Source m (yd) Range of Foliage Concentrations Within Area of Elevated PCB ug/g (ppm) FDA Standard for Forage Crops ug/g (ppm) 700 (770) 400+ (440+) 0.1 to 58 0.1 to 51 0.2 0.2 150 (170) 0.1 to 3 0.2 200 (220) 0.1 to 1.4 0.2. Source: Buckley, 1980. 3-35 HONS 009886 Table 3-7 Foliage PCS Level* Hear fort Miller Duapsite Distance from Duapsite (yd) 73.5 (80.4) 89.0 (97.4) 132.1 (144.5) Mean Weekly PCB Concentration in Air ug/cu n 0.19 0.14 0.08 Corn, Cjrain and Cob ug/cu n 0.13 0.14 0.06 Corn, including Stem, Leaves,.Ears and Tassle ug/g (ppm) 0.91 0.67 0.40 A1falfa* Red Clover * Timothy* ug/c (ppm) 1.35 0.95 0.56 ug/g (ppm) 3.2 2.4 i .4 Note 1. FDA standard for forage crops is 0.2 ug/g (ppm) 2. Estimates based on data for other crops Source: Buckley, BTl, March 24, 1981. O4J O' MQNS 0 0 9 8 8 7 treat except those usually expected from water and nutrient deficiencies (Buckley, 1980). Reduced plane growth, however, has been docuieeneed in a crop species (soybeans) growing in soils containing 1,000 ug/g (ppm) Aroclor 1254 (Weber and Mrozek, 1979). 4c. Fauna The terrestrial fauna at the proposed containment site consists of a variety of birds and small mammals common to woodlots and fields. Likely inhabitants of the area include opposum, racoon, porcupine, cottontail rabbit, whitetail deer, several species of field mice, rats and moles, and numerous species of birds. Burrowing animals that may be present include woodchucks, red fox, skunk, muskrat, and weasel (MPI, 1980a). Because the land is not significantly wooded, the area is not a preferred habitat for most of these animals, except woodchucks, mice, rats, moles, and birds. 4d. Agriculture Dairy farming is a major industry in the upper Hudson River region and 180 active farms sre located within a 16-km (10-mi) radius from the proposed PCB containment site. The dairy farma are small to moderately sized and are pre dominantly family owned. The approximate total investment for farm operation is $4,000 to $5,000 per cow. Replacement costs per cow are estimated at $1,000 to $3,000 (Beaty, CAC, March 28, 1981). Most of the crops grown in the region, such as corn, alfalfa, clover, and other forage crops are used to feed dairy cows. The selling value of these crops is estimated at $18 to $23/t ($20 to $25/tn) for corn silage and $54/t ($60/tn) for graas hay. Cost to the farmer from a dealer is estimated at $32 to $41/t ($35 to $45/tn) for corn silage and $54 to $73/t ($60 to $80/tn) for hay (Beaty, CAC, March 28, 1981). The proposed containment site could yield 20 to 27 t/ha (9 to 12 cn/a) per year of corn for silage, or 5.4 to 9.0 t/ha (2.4 to 4.0 tn/a) per yeer of forage mixture. Such yields would sell for $370 to $740/ha ($150 to $300/a) per year. 3-37 HONS 009000 The pasture season, when Che cows consume pasture forage, usually lascs from May Co October. During Che remainder of the year, the cows esc winter radon* of corn silage and hay. The feed allowance for each "mature Holstein is approxi mately 4.5 to 6 t (5 to 7 tn) of good hay-equiveient during the winter season and 5.5 to 7.5 t (6 to 8 tn) of good hay-equivalent during the pasture season. (One unit of good hay is equivalent to three units of silage, or two units of haylage.) A dairy cow generally remains in the herd for less chan seven years. Each cow has one lactation per year and produces 6,300 to 7,300 kg (14,000 to 16,000 lb) of milk per year. A lactating cow drinks approximately 150 l (40 gal) of water per day to produce milk that is approximately 37 to 90 percent water (Newton, February 27, 1981). As previously discussed, low levels of PCB are found in forage crops in Washington and Saratoga counties. Measured PCB levels occasionally exceed the FDA limit of 0.2 ug/g (ppm) in animal feed. There has been concern that milk from cows consuming contaminated forage might exceed the FDA limit of 1.5 ug/g (ppm) for PCBs in dairy products, especially because PCBs are known to con centrate in milk. Aroclor 1254 accumulates in milk by a factor four to five times greater than the levels of 1254 in feed. But it has been determined that milk produced in the region doea not contain PCBs over the FDA limit, as in dicated by the following paragraph (MP1, 1980d). The New York State Department of Agriculture and Markets has periodi cally sampled milk produced in Washington and Saratoga Counties for PCB contamination. Most recently, potentially contaminated farming areas were delineated by the State Department of Health (NYSDOH), and milk on eight farms in these areas was tested for PCB on June 12, 1979. All eight milk samples measured less than 0.2 ug/g total PCB on a fat basis, well below the FDA standard of 1.5 ug/g ... In addition to dairy products, poultry products, calves, heifers, pure bred cattle, and relatively small quantities of cash crops are produced in the region (Slocum, February 9, 1981; Stork, February 9, 1981). 5. THREATENED OR ENDANGERED SPECIES A substantial population of endangered shortnose sturgeon exists in the 3-38 MOMS 009669 Hudson River estuary. Most of the population probably occurs between Csopus Meadows (River Mile 87) and the Troy Dam (River Mile 154). This reach of the Hudson River encompasses the spawning area, the major overwinter area, the important nursery area for young-of-the-year fish, and a substantial portion of the summer feeding ground. Young-of-the-year shortnose sturgeon feed extensively on benthic species between River Mile 140 and Kingston (River Mile 92) (Dovel. Oceanic Society, February 23, 1981). The vitality of the shortnose sturgeon population is probably more sus ceptible to harm from toxic chemicals introduced into the upper Hudson River than any other species of fish inhabiting the estuarine ecosystem, including the commercially valuable American shad and striped bass. The extreme vulnerability of the sturgeon may be attributed to its occurrence and spawning in a highly polluted 12.4-km (20-mi) segment of the estuery immediately south of the Federal Dam at Troy (Dovel, Oceanic Society, February 23, 1981). Approximately 75 percent of adult shortnose sturgeon over 75.0 cm (29.5 in) in total length have fin rot. In some cases, this fin rot is very severe, but the agent that causes the disease has not been positively identified. However, high prevalence of fin rot haa been shown to be associated with ecologically degraded coastal areas (Murchalano, 1980). It is possible that toxic substances in the water column lower the natural inunity of shortnose sturgeon to infes tations of a fungus, tentatively identified as Leptolcgria caudate. For example, PCBe have been shown to increase the number of virus infections in the pink shrimp of the Gulf of Mexico (Murchelano, 1980). The fin rot common on adult shortnose sturgeon in the Hudson River seems to be sublethel, but the disease probably imposes a substantial stress on affected individuals (Dovel, Oceanic Society, February 23, 1981). The apparent low survival of newly fertilized eggs may be a critical factor limiting the size of the shortnose sturgeon population in the Hudson River. In 1979 and 1980, the hatching success of laboratory-reared eggs was greatly impaired by Che fatal penetration of fungus (Dovel, 1979). Eggs held in Hudson River water became totally overwhelmed by the fungus in less chan 24 hours, whereas eggs held in spring water remained generally free of the fungus for a much longer period. 3-39 MOWS 009890 There seen to be substantial sublethel and lethal impacts on the shortnoae sturgeon that may indirectly result from a deterioration of the natural water chemistry due, in part, to the presence of toxic chemicals, especially PCBs (Dovel, Oceanic Society, February 13, 1981). A sturgeon with a concentration of 998 ug/g (ppm) PCBs in fatty tissue around the brain was alive when caught (Dovel, I960). However, there is no way to measure the sublethal stress experi enced by such contaminated fish. It is fairly obvious that the shortnoae stur geon of the Hudson River is a bioaccumulator and bioconcentrator of PCBs and probably other toxic chemicals, such as pesticides and heavy metals. The present condition of the shortnoae sturgeon population is unknown; it could be stable or approaching collapsa (Dovel, Oceanic Society, February 23, 1981), No other rare or endangered species are known to inhabit the Hudson River, and none are known to inhabit or frequent the area of the proposed containment aite. Protected species, such as the osprey and northern bald eagle, may pass over the region during migrations through the Hudson River valley. 6. ENVIRONMENTALLY SENSITIVE AREAS Areas that are classified as being environmentally sensitive include priow agricultural soils, wildlife refuges, critical habitats of rare or endangered species (as designated by USFVS), aquifer recharge areaa, scenic or recreational araas, floodplains, wetlands, cultural resources, and steep slopes. Most of these categories either do not exist in this ares or are not affect ed by any of the alternatives under consideration. Wetlands and the habitats of rare or endengered species have been discussed in section 3 of this chapter. Prime agricultural soils are not present on the propercy proposed to be acquired for a containment facility. Cultural resources, scenic and recreational areas, and floodplains will be discussed below. 6s. Cultural Resources In conformance with federal and scats laws and implementing regulations, a preliminary cultural resource investigation (Stage I) was conducted for the PCB containment facility at Site 10 in the Township of Fort Edward. The purpose of 3-40 HONS 009091 f Che investigation wee Co identify historic end archaeological properties on, or eligible for listing on, Che National Register of Historic Places. The Stage I cultural resources study was conducted in the Township of Fort Edward at Che proposed containment site. The study was divided into two compon ents: a literature search (Stage la) and a field investigation (Stage lb). The literature search consiated of a detailed review of existing site files, inter views, deed research, examination of histories and maps, a walkover, and drivearound the area. As a result of Che literature search, the following resources were identified within the project's proposed impact area: trolley line (Hudson Valley Railroad right-of-way), the Old Champlain Canal, a property listed on the National Register of Historic Places, a old barn complex, and a house and barn complex. The literature search also provided the data for the derivation of a his toric and prehistoric sensitivity model. From this preliminary inspection and research, it was determined that a field inveatigation (Stage lb survey) was needed to identify prehistoric and historic archaeological site locations. To locate archaeological sites, shovel test pits were placed at varying intervals at selected locations within the project area. This sampling method ology was based on the derived sensitivity models. Table 3-8 summarizes all cultural resources identified during the Stage I study. No further work is recommended for thoae resources chat do not appear to meet the eligibility criteria for the National Register of Historic Places. The archaeologieally sensitive Dead Creek ia outside the project impact zone and will bs avoided. Mitigation plans are presently being developed for the Champlain Canal area. For the remaining eight cultural resources, further inveatigation will be conducted in early spring. Historic structures will be evaluated by a qualified architectural historian in consultation with New York State Historic Preservation Office (SHPO). Subsurface testing will be conducted 3-41 MOMS 009892 Table 3-8 Summary of Cultural Resources Identified at Site IQ Cultural Resource Description RecommendeCion 1. Historic Dump 1 historic, surface no further work 2. Historic Dump 2 historic, surface no further work 3. Old Barn Complex 4. Garage or Equipment Shed historic structure historic structure further identification further identification 5. New Barn Complex historic structure further identification 6. House 7. Hudson Valley Railroad historic structure historic, destroyed further identification no further work 8. Champlain Canal National Register Site historic structure develop mitigation plan 9. Concrete Foundation historic further identification 10. Stone and Concrete Foundation historic further identification 11. Hudson South prehistoric further identification 12. Hudson North prehistoric further identification 13. Dead Creek Bank prehistoric? avoidance 3-42 HONS 009893 at the identified archaeological sites to evaluate their potential eligibility for the National Register of Historic Places (Stage II). 6b. Scenic and Recreational Areas Water quality c1asaificaeons for the upper Hudson River vary from "A" to"D." These classifications are based on the "best use" intended for these waters (Appendix E). Except for the stretch of water from the mouth of the Batten Kill to Lock 3 ("B"), and the section below Lock 2 ("A"), these waters are intended for secondary contact recreation, primarily boating and fishing. However, since 1976, commercial and recreatioaal fishing have been prohibited in the upper Hudson River between Fort Edward and the Troy Dam because of the high PCB concentrations in fish (greater than 5 ug/g [ppm] PCBs). It has been es timated that the annual value of the recreation fishery in the upper Hudson River would be $1,250,00 (in 1976 dollars) (Sheppard, 1976), The waters of the upper Hudson River continue to be used by recreationel boaters. Recreational fishing is permittad in the lower Hudson River below the Troy Dam. The taking ot American eel, however, is prohibited. Sheppard has assigned an annual value of $1,350,000 (in 1976 dollars) to the recreational fishery in the lower Hudson River. These waters are suitable for secondary contact re creation. 6c. Floodplains and Wetlands The Hudson River between Troy and Glens Falls is bordered by terraced pcoglecial lake deposits and bedrock cliffs. The floodplain of the upper Hudson River in the area is long and narrow, confined largely to areas adjacent to the river. The 100-year flood last occurred on April 2, 1976. A small creek (Dead Creek) crosses the southeast corner of the containment site property. The extent of floodplain for this creek varies between 75 and 150 m (250 and 500 ft) from the center of the stream bed. Neither the Hudson River floodplain nor the Dead Creek floodplain will infringe on the containment faci lity. Wetlands are found on Che containment site and are described in section 4a of this chapter. 3-43 HONS 009894 Several wetlands along the upper Hudson River have been designated aa hot spots. A discussion of these areas and their location is represented in section 3b of this chapter. Because of their value as wildlife habitats, several of these wetlands should be retained, or restored, irrespective of any remedial action involving the hot spots. 7. AIR RESOURCES 7s. Climate The following section is an adaptation of Dredging of PCB-Contaminated River Bed Materials, Upper Hudson River, New York (MPI, 1978a). The climate of the upper Hudaon River Valley from Glens Falls to the Troy-Albany area ia generally a humid continental type. Specifically, cold winters and warm, sometimes humid, summers are typical. Mean minimum temperatures in January for Glens Falla and Troy are -12C (10F) and -9C (16?), respectively. July swan maximum temperatures for the same two locations are 30C (86F) and 28C (83F) (United Stated Department of Commerce [USDC), 1974). Average annual temperatures in 1976 for Glen Falls and Troy, were about 6C (43F) and 8C (47'F), respectively. The length of the freeze-free period for Ciena Falla in 1976 was 133 days, extending from mid-May to the end of September. The freezefrac period in Troy covered the period from mid-April to mid-October, for a total of 182 days (USDC, 1976). Precipitation in the Hudson River region is uniformly distributed throughout the year. The minimum precipitation usually occurs during the winter months, and the maximum during the summer months. For Glens Falls, mean annual precipita tion, calculated over a period of 20 years, is approximately 100 cm (40 in). Mean annual precipitation for Troy ranges around 90 cm (36 in) (USDC, 1976). A rainfall intansity-duraeion-frequency curve for Albany is depicted in Figure 3-1 (USDC, 1955). This curve indicates the frequency, in years, of a rainfall of a given intensity in inches per hour and a given duration in minutes or hours. The Hudson Valley generally has a continuous snow cover from mid-December to mid-March, with maximum depths occurring in February. Mean total snowfall in both Glen Falla and Troy is approximately 150 cm (60 in) per season (USDC, 1974). 3-44 HONS 009895 Figure 3-1 H.infin Intenaity-Ouracioti-Frequency Curve1 for. Albany. Hew York (1903-19511 OmilQN Frequency enely.U by method o excreme veluee, efcer Cumbel Not*: 1. Source: e. MPX,. 1978" HONS 009896 Wichin Che Hudson River region, average pan evaporation and lake evaporation have been calculated to be about 90 cm (35 in) and 70 cm (27 in), respectively (USDC, 1959). Wind speed and direction data for Glen Falls and Rensselaer are given in Tables H-l and H-2 (Appendix H). Winds at the containment site are affected by local topography and ocher conditions. However, local meteorlogical data for the containment site is not available. 7b. Air Quality The following is an adaptation and update of Dredging of PCB-Contaminated River Bed Materials. Upper Hudson River, New York (MPI, 1978a). Total suspended particulates were monitored with high volume air samplers at five stations in the general vicinity of the study area. These stations included two in Glens Falls and one each in Fort Edvard, Mechanicville, and Troy. At one Glens Falls station and in Fort Edward, Mechanicville and Troy, both the annual geometric means for 1975 through 1979 and the 24-hr average concentrations of total suspended particulates were veil under the atate and federal standards (Table 3*9). While the federal standard is uniform, state standards vary, depending on the economic development and associated land uses of the region. The other Clens Falls station did exceed the standard for the annual geometric mean in 1975. The 1976 mean showed an improvement and subsequently, this site was in compliance with the state standard of 55 ug/cu m for each successive year through 1979. The 1979 24-hour maximum averages at all sites listed in Table 3-9 were well below the 250 ug/cu m standard (NYSDEC, 1979). Settleable particulates are monitored in Glens Falls and Troy with the use of 30-day dustfall jars. These results are summarized in Table 3-10 (NYSDEC, 1979). A PCB air sampling study has been undertaken at five locations in Che upper Hudson Valley. This program involves simultaneous sampling at each of the sites eveTy six days for 24 hours. Data in this program collected between January and August, 1977 are presented in Table 3-11. The stations in Glens Falls and Warrensburg recorded the lowest PCB values with readings generally less than 3-45 MONS 009897 Table 3-9 Total Suspended Particulates from High Volume Air Samplers at Selected Stations, Upper Hudson River, 1979 Station Glens Falls Glens Falls Fort Edward Federal Standard ug/cu m 75 75 75 NYS AAQS Geometric Mean Level ii3 4 ug/cu m 55 III 65 II 55 Annual Geometric Mean (ug/cu !*) (not to exceed AAQS G.M.) 1975 63* 1976 45 1977 41 1978 34 1979 37 49 43 45 41 45 NA5 36 33 33 36 24-hour Avg ug/cra m (not to exceed 250 ug/cu m) 1st Max^ 2nd Max 3rd Max 90(0) 72 71 134(0) 133 116 144(0) 92 78 Mechanicvi1le 75 11 55 NA 45 39 39 44 110(0) 106 105 Troy 75 111 65 46 39 36 33 36 71(0) 68 65 u> i o> Notes: 1. New York State standard for 24-hr average is 250 ug/cu a; federal standard is 260 ug/cu m. 2. 1st, 2nd and 3rd maximum averages measured during 1976. The number in parentheses indicates number of times 24-hr max was exceeded. 3. The state is divided by air quality priorities into four levels: level I, denoting areas of least pollution to level IV, areas of heaviest pollution. The two Glens Falls stations are located in areas with different levels, thus the difference in the AAQS values. MOMS 0 0 9 8 9 8 4. Denotes a violation of Ambient Air Quality Standards. 5. NA " Not Applicable. Source: NYSDEC, 1979. Table 3-10 Settleable Particulate* from 30-Day Dustfall Jars Annual Average* 1976 to 1979 and Monthly Averages in 1979 at Selected Station*, Upper Hudson River NYS Annual Standard NYS AAQS1 Ceometric Means and 50/84 Annual Arithemtic Mean 2 (mg/cm /mo) Monthly (30-day) Avg.-19792 2 (mg/cm /mo) Scat ion Level K/cn2/no ft/cm^ /mo 1976 1977 Glens Falls II 0.30 0.30/0.45 0.39 0.26 Troy III 0.40 0.40/0.60 0.33 0.23 Notes: 1. 50th percentile value/84th percentile value. 1978 NA NA 1979 0.23 NA Max 0.66 0.47 2nd Max 0.24 0.34 3rd Max 0.21 0.27 2. Under monthly average 1979, the 1st, 2nd, and 3rd maximum 30-day averages were measured from January 1 to December 31, 1979. waI* 3. NA * Not Available. Insufficient data were available to formulate an annual arithmetic mean. Source: NYSDEC, 1979. HONS 0 0 9 8 9 9 Table 3-11 PCB Air Sampling by Che New York Scatc Department of Health nannograra/cu m Dace Glens Falls 5601-4 Warrensburg 5660-02 Stations Hudson Falls 5726-01 Fort Edward 1 5755-01 Fore Edvard II 5755-02 1/1/77 1/7/77 1/13/77 1/19/77 1/25/77 1/31/77 2/6/77 2/12/77 2/18/77 2/24/77 3/2/77 3/14/77 3/20/77 3/26/77 4/1/77 4/7/77 4/13/77 4/19/77 4/28/77 5/3/77 5/13/77 5/19/77 5/25/77 5/31/77 6/6/77 6/12/77 6/18/77 R R R LA R <20 <20 <20 <2G R <50 <20 R <20 <20 <20 <20 <20 <20 <20 <20 <20 R <20 <20 <20 R R LA R <30 <40 <20 <20 <20 <20 <20 <30 <20 <20 <20 <20 NR <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 R R 40 <or-190 LA R R 50 80 130 <20 <20 190 <20 <20 <20 100 120 160 260 30 <20 <20 200 100 30 20 R R R 1020 530 1800 1000 STB 500 360 870 <or600 <or*60* <or-320 140 100 1250 1180 740 3060 330 850 580 1140 970 R 130 90 <30 R <or60 <20 R <30 <20 20 40 280 80 560 1 <or*70 240 130 <20 160 200 <20 210 120 100 130 <20 320 30 R 3-48 HONS 009900 Table 3-11 (continued) Dste Glens Falls 5601-4 Warrensburg 5660-02 Stations Hudson Falls 5726-01 Fort Edward I 5755-01 Fort Edward 11 5755-02 6/24/77 6/30/77 7/6/77 7/12/77 7/18/77 7/24/77 7/30/77 8/3/77 8/11/77 8/17/77 R <20 <20 <20 <20 <20 <20 R R <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 R n2 140 50 50 100 30 120 R R R 3260, 1502 290 350 520 590 R R 480 30 <20 70 <20 <20 <20 <20 <20 R <20 5601*04 Continuous Air Monitoring Station, Glens Falls 5660-02 DEC Region 5 Suboffice, Warrensburg 5726-01 Main Street School, Hudson Falls 5755-01 Washington County Office Building, Fort Edward 5755-02 Fort Hudson Nursing Hone, Fort Edward 1 nannogram - 1,000 micrograma R Reject LA Lab Accident STB Sampling Train Broken NR Not Run Notes: 1. Appear to have been switched but cannot be verified. 2. Results are inconsistent with each other: 5726-01 is usually ten percent of 5755-01. Source: NYSDEC, 1977 b. 3-49 MOMS 009901 The Hudson Falls and two Ford Edvard stations recorded higher PCS levels, perhaps because of proximity to the GE facilities in Ford Edvard. One Fort Edward station, immediately northeast of the GE plant, recorded the highest concentrations of the five stations, with values ranging from around 0.06 ug/cu m to a maximum of 3.26 ug/cu m during the eight-month period. The other nearby Fort Edvard sampling station registered a maximum PCB value of 0.56 ug/cu m. The mean PCB levels at this station were the second highest of the five stations. Hudson Falls followed with monitoring results indicating PCB concentrations significantly greater than Glens Falls and Warrensburg but less chan the two Fore Edvard stations (NYSDEC, 1977). Thirty-day dustfall jar tests, which are used to measure aettleable particu lates, have also been conducted for three stations in Fort Edward, Glens Falls, and Warrensburg (NYSDEC, 1977). Samples were collected monthly from February to July 1977, and the results expressed as a total amount of PCBs per jar, PCBs per gram of particulate matter, and amount of particulate matter per unit area. In the two categories related to PCBa, the Fort Edward station was markedly higher than the Glens Falls or Warrensburg stations. Values of PCBs were less than 0.02 ug/cu m for each reading at Glens Falla and Warrensburg, but ranged between 0.13 and 0.93 ug/cu m for the Fort Edward station. Similarly, the micrograms PCB per gram particulate matter ranged from less than 0.6 to less than 3.0 ug/cu m for Glens Falls and Warrensburg, but from 8 to 29 ug/cu m at Fort Edvard. The accumulation of particulate matter, however, was only slightly greater at Fort Edvard than at Glens Falls, while both Cations had considerably higher levels than Warrensburg. These results indicate that settleable solids are more prevalent at Fort Edward than Glens Falls and have much higher associated PCBs. Settleable solids at Warrensburg are both reduced in quantity and less contaminated with PCBa. The Fort Edward station is, again, located immediately northeast of the the GE plsnt. It should slso be noted that the above results are unpublished and subject to revision. 3-50 HONS 009902 The following includes new information not previously reported in Dredging of PCB-Concaminated River Bed Materials, Upper Hudson River, New York (MPI,1978a). A field study was performed by NYSDEC (Tofflemire, 1981) on PCB concen trations at site 10 near the Delong Farm and the Lock 6 dam at the Cottrell Paper Company (Table 3-12). The highest concentrations of PCBs were found at the Lock 6 Dam site for Aroclor 1016. The NYSDEC measured PCB concentrations outside the Washington County Office Building in Hudson Fails, New York from November 1976 to December 1977 (Figure 3-2). As evidenced by the figure, the average PCB concentration dropped from approximately 1 ug/cu m to about 0.3 ug/cu m after the cessation of PCB use at the GE plant in July, 1977. NYSDEC measured PCB concentrations in air at several sites in the Fort Edward and Hudson Falls area (Table 3-13). As indicated by the table, it appears that the highest PCB concentrations occurred at the Caputo Dump site. However, ome discrepancies in sampling method and duration have been noted and as a reault, these data may not be appropriate for the purpose of comparisons. 3-51 HONS 009903 Table 3-12 Ambient PCB Levels at Site 10 and Lock 6 Dam Sice Date Hrs. of Sampling 1016 PCBs ug/cu m Aroclor 1221 1254 Site 10 by Delong Farm 8/25/80 8/26/80 19 1/2 Site 10 by Delong Farm 9/05/80 9/07/80 48 Lock 6 Dam at Cottrell Paper 8/25/80 8/27/80 48 Lock 6 Dam at Cottrell Piper 9/05/80 9/07/80 48 Source: Tofflemire, NYSDEC, March 11, 1981 <.02 <.02 <.02 <.01 <.01 <.01 <-11 <.01 <.01 <.52 <.01 <.01 3-52 MONS 009904 Figure 3-2 PCB CONCENTRATIONS IN AMBIENT AIR AT WASHINGTON COUNTY OFFICES S0 6 6 0 0 SNOW PC* (BltdMi S NTS OCC *f NTS DOM Table 3-13 Summary Tabulation of Air PCB Data by NYSDEC Division-of Air Reeources Data taken at Temperature of 18 to 29 (63 to 85F) Sice Caputo Dump Caputo Fort Miller Dump Remnant Area Moreau aite with excavated 3A material Buoy 212 site Summer 1979 Old Moreau Site Summer 1979 Comment Max Avg Max Avg Max Avg Max Avg One Sample 29 (85F) Avg Air PCB ug/cu m 300 130 35 Ik 10 9 15 5.6 0.7 0.3 Sediment ug/g (ppm) 10,000-50,000 10,000-50.000 5,000-15,000 5,000-15,000 1,000-2,000 1,000-2,000 600-1,000 600-1,000 50-100 20-50 3-53 MONS 009906 CHAPTER 4 ENVIRONMENTAL CONSEQUENCES OF FEASIBLE ALTERNATIVES This chapter presents a discussion of the environmental impacts of the feasible alternatives proposed co address the PCB problem that exists in the Hudson River. The evaluation will draw on the alternatives presented in Chapter 2 and the scientific evaluations presented in Chapter 3 of this document. How ever, the environmental impacts of all the options discussed in Chapter 2 are not presented because some were found to be infeasible and/or ineffective. Specific alternatives, including Control of River Flows, In-River Detoxifi cation, Physical Treatment/Destruction of Dredged Spoils, and Bank-to-Bank Dredging were found to be infeasible because of costs and technical consid erations and are not analyzed further. The remaining altarnatives, including No-Action (with and without routine maintenance dredging). Dredging Alternatives (the Full-Scale Project and ReducedScale Project), In-River Containment of Hot Spots, Remnant Deposit Alternatives, Dredging Mechanism Alternatives, and Dredge Spoil Disposal Alternatives, were evaluated for potential beneficial and adverse, short- and long-term impacts undar normal river flow as well as high-flow conditions. By definition, primary impacts are those adverse or beneficial impacts that are associated with the construction and operation of a proposed project. Secondary impacts are those adverse or beneficial impacts that are induced or result indirectly from the proposed project. The major factors considered in the assessment of primary and secondary impacts arc: Public Health - Protection of downstream water supplies - Reduction of volatilisation from remnant deposits and dredge spoil areas - Reduction of containment site volatilization - Reduction of exposure through the ingestion of contaminated fish - Protection of groundwater in the area of the containment site a Fiahtries and Aquatic Biota - Permanent reopening of the commercial and recreational fisheries - Protection of endangered species (shortnoaed sturgeon) - Reduction of the bioaccumulation of PCBs through the food web - Protection of wetlands 4-1 MONS 009907  Maintenance Dredging and Navigation - Mitigation of future maintenance dredging and disposal problems in the upper Hudson Basin as well as the estuacy - Evaluation of impacts to future hydroelectric dam construction and usage Agriculture - Reduction of volatilization from remnant deposits and dredge spoil areas - Reduction of containment sita volatilization - Protection of groundwater in the area of the contaminant sice - Protection of crops and livestock in the area of the containment site The recommended action is comprised of the following alternatives: Full-Scale Project, Major Alternatives section 4 (if funding becomes available) Reduced-Scale Project, Major Alternatives section 5 In-River Containment, Alternative Components section 1 (wherever cost-ef fective) Containment Site, Alternative Components section 4 I. MAJOR ALTERNATIVES 1. The No-Actlon Alternative 1A. No-Action Alternative (Assuming That Routine Channel Maintenance Dredging Will ContimieT "* la. Short-term Primary Impacts Under this alternative, there will not be adverse short-term primary impacts because PCB-contaminated sediments will not be removed from the Hudson River. This alternative does not provide for the stabilization and/or removal of remnant deposits, or the removal of NYSDOT Spoil Site 204 Annex. In short, this no action alternative would allow the total mass of PCBs to remain in the banks and bad of the Hudson River, except for that removed by maintenance dredging, volatilization and transport downstream. The continued dispersion of PCB in such a way could present long-term adverse impacts, as described below. 4-2 MOWS 009908 The beneficial primary impacts of this alternative include the avoidance of short-term construction related effects such as noise, truck traffic, destruc tion of wetlands and resuspension of sediments. lb. Long-term Primary Impacts Under this no-action alternative, long-term adverse impacts can arise because the total mass of PCBs will remain in the Hudson River system, allowing the continual release of the toxic chemical to the air, water and biota. Routine maintenance channel dredging and volatilisation will remove PCBs from the river. Table 2-2 indicates chat it would take 33 years from the present date for all the PCBs in the upper Hudson River either to be transported into the estuary, to be volatilized, or to be removed by routine navigational dredg ing. Under this no-action alternative, 82,800 kg (182,000 lb) would be carried over the Federal 0am at Troy, 22,500 kg (49,500 lb) would be volatilized, and 37,400 kg (82,500 lbs) would be removed by routine maintenance dredging. The long-term primary impacts that could arise from this ao-ection al ternative include: potential long-term threat to downstream public water supply; continued risk to the public associated with exposure to PCBs from uncontrolled volatilisation and direct contact; continued availability of PCBs to the food chain from both the terrestrial and aquatic media; continued threat to the commercial and recreational fisheries of the Hudson River; and a threat to the continuation of routine maintenance dredging operations. Public Health An evaluation of the impact of the no-action alternative on public health should include a definition of background levels of PCBs in all media that lead to human exposure and an evaluation of the toxic effects and health impacts associated with such exposure. Routes of exposure include drinking water, inhalation, ingestion, and dermal absorption. Routes and degrees of absorption of PCBs through the skin sre unknown, and exposure through this route is unquantifiable, although subjectively estimated to be small relative to other exposure routes. (Appendix A). 4-3 MONS 009909 A* described in section 2 of Chapter 3, background levels of PCBs in Che Hudson River are approximately 0.6 ug/1 (ppb) and have remained steady through the three monitoring years of 1977, 1978, and 1979 (Toffiemire, KYSDEC, 1980). Water treatment by activated carbon filtration can reduce these levels by 40 to 80 percent (Cranston, City of Poughkeepsie, August 25, 1977), but such treatment is presently not used by Hudson River communities. Residents using treated Hudson River water for consumption would consume about 0.6 ug/day of PCB* (at a consumption rate of 2 liters/day [lpd]). Residents consuming untreated river water, could be exposed to levels of up to 1.2 ug/day. This situation could become worse and actually increase in areal extent under a flood situation where PCB-laden sediments from hot spot areas would be resuspended and carried further downstream. Based on comprehensive national food surveillance programs from 1971 through 1975, FDA has estimated the average daily intake from all food group composites snd the average daily intake from the meat-fish-poultry class (Table 4-1). The decrease in total dietary exposure is due to decreasing levels of PCBs in food packaging materials. The ingestion of PCBs through food should level out (based upon national background levels) and continue at the 1975 level as long aa fish remain almost the sole source of dietary PCBs. The populace in Fort Edward and Hudson Falls is exposed to an outdoor general background PCB concentration of 0.05 to 0.10 ug/cu m (Kerr, NYSDEC, May 8, 1980) and the rural populance is exposed to concentrations of less than 0.01 ug/cu m (Buckley, BTI, April 9, 1981). Residents and livestock in the ares of existing PCB dumpsites and dredge spoil disposal sites and remnant sites can be exposed to levels above background levels. For example, at several PCB dump aitea in the Fort Edvard and Glens Falls areas, concentrations exceeded the NI0SH 8-hour recommendation of 1 ug/ cu m, with levels at the Caputo site of up to 130 ug/cu m during the summer (MPI L980d). Soil concentrations of PCBs at the Caputo site were 10,000 to 50,000 ug/g (ppm). As discussed later in this chapter, the general public health risks asso ciated with the no-action alternative are greater than those associated with any of the feasible action alternatives. 4-4 MQNS 009910 Table 4-1 Estimates of Total Daily PCB Ingestion Average Daily Ingestion of PC8s (ug/day) Fiacel Year Total Diet Meat-Fish-Poulty Class 1971 1972 1973 1974 1975 15.0 12.6 13.1 8.8 8.7 9.5 9.1 8.7 8.8 8.7 Source: EPA, 1976b. 4-5 HONS 009911 Fisheries and Aquatic Biota Under the no-action alternative, contamination of fish in the Hudson River will continue. Based on 1980 data, most fish species in the upper Hudson River contain PCBs at levels exceeding the FDA tolerance level of 5 ug/g (ppm). A number of species in the lower Hudson River, including striped bass, white perch, and eel, also contain PCBs above the FDA standard (Appendix G). As discussed in Chapter 3, section 3, PCB levels in Hudson River fish heve sub stantially declined since testing began in 1976 and 1977. Collective decreases in total PCBs averaged 38 percent from 1977 and 1978 (Armstrong and Sloan, 1980) . The overall decline was mainly caused by decreases in Aroclor 1016, which is less stable in the environment than the more highly chlorinated aroclors. The 1980 fishery data indicate that the decline in fish PCB levels may be leveling off. Aroclor 1016 continued to decline, but Aroclor 1254 de clined very little, if at all, from 1979 to 1980 (Sloan, NYSDEC, March 10, 1981) . Under the no-action alternative, it seems likely that PCB levels will not decline to the acceptable limit until the late 1980s at the earliest. For lergemouth bass and other resident fish in the upper Hudson River that have PCB levels well above the limit, PCB levels would decline to below 5 ug/g (ppm) in approximately five or six years, assuming that the rate of decline over the past three years continues. In the lower Hudson River, resident fish, such as white perch and some striped bass, would not have acceptable PCB levels until the late 1980s at the earliest. However, the rates of decline that occurred from 1977 to 1980 probably will not continue because the declines were mainly due to the cessation of PCB discharges by GE, the low flow conditions on the river, removal of some contaminated materials by maintenance dredging, and by the removal of remnant deposit 3A, the stabilisation of remnant deposits, and the breakdown of the lower chlorinated eroclors. PCB levels in fish may tend to stabilize around a level in equilibrium with levels of PCBs released from river sediments. If a future flood causes extensive resuspension of PCB contamineted sediments, declines in PCB levels in fish could be halted or even reversed. There is evidence that fish can accumulate PCBs from the water column quite rapidly 4-6 HONS 0099 U (Armstrong and Sloan, 1980). A flood event that elevates PCB levels in the Hudson River for one to two weeks could cause increases in fish PCB levels. PCBs accumulated in such a way would persist in the fish indefinitely because of the long retention time of PCBs in fish flesh. Under the no-action alternative, it is unlikely that PCB levels in fish will reach the FDA limit that would allow the fishery to be reopened during the next ten years. The continued release of PCBs from sediments and the likelihood of floods could combine to keep the fisheries closed. The lowering of the limit to 2 ug/g (ppm), as proposed by FDA, would keep the fishery closed indefinitely. The one exception is American ahad. Mean PCB levels in shad were found to be below S ug/g (ppm) when testing began in L976. After significant declines from 1976 to 1978, PCB levels in shad seem to have stabilized around 1.5 ug/g (ppm) (Appendix C). Contamination of Hudson River fish will continue to impose health risks on Che public. Despite the ban on fishing, illegal commercial fishing, sport fishing end subsistence fishing do cake place on Che Hudson River, and consumers are eacing fish with PCB levels exceeding Che FDA limit (Blumenthal, Mew York Times, April 3, 1981). Since FDA data collected in 1975 indicate that the meat-fish-poultry food category is primarily responsible for dietary intake of PCBs, suspension of the ban on fishing in the upper Hudson River must be considered for its effects on local population dietary exposure to PCBs. For people along the Hudson River that do not consume fish tsken directly from the river, exposure to PCBs through the ingestion of food would be at least 9 ug/day, the national background level (USEPA, 1976b). Consumption of Hudson River fish with PCB levels at the FDA action level of 5 ug/g (ppm) would increase this level to approximately 900 ug/day, based upon an average daily consumption of 200 grams (0.4 lbs) of fish (USFOA, 1979). Agriculture and Terrestrial Biota The no-ection alternative would allow the continued volatilization of PCBs from remnant deposits, from Che banks and bed of the Hudson River, end from existing dredge dispose! sites. This situation poses a potential threat to the 6:A-08 4-7 HONS 009913 dairy industry immediately adjacent to these uncontrolled disposal, sices through Che volatilization process. Forage crops contaminated with PCBs could be in gested by dairy cows, increasing the risk that milk could be contaminated with PCBs. Another agricultural concern associated with the no-action alternative regard* the potential risk of using Hudson River water (without treatment) for dairy herds. Volatilization from existing PCB sources will also continue to contaminate adjacent flora and fauna, allowing biomagnification of PCBa to occur in the terrestrial ecosystem. Maintenance Dredging and Navigation The USACOE requires toxicity testing of dredge spoils before permitting ocean disposal. Such tests have indicated that PCB concentrations greater than 4 ug/g (ppm) in dredge spoils would likely preclude ocean disposal, es pecially if heavy metals and other toxic contaminants are present (Curll, Save Our Ports, March 24, 1981). There are sediments in areas of the lower Hudson River which are not now suitable for ocean disposal. PCB levels in the Albany turning basin are expected to continue to increase until the year 2013 under this alternative. This would preclude ocean disposal of these dredge spoils. At present the average PCB concentration in New York Harbor is 3 ug/g (ppm) with some areas exceeding 4 ug/g (ppm) (Bopp, 1981). The average PCB concentation in New York Harbor sediments is expected to increase under the no action alter native, but local increases in PCB concentrations are likely to occur. A beneficial impact associated with the no-action alternative (assuming that routine maintenance channel dredging will continue) is that, although the removal of PCB-contaminated sediments as proposed by the NYSDEC would not be implemented, future routine maintenance dredging operations would inadvertantly remove PCB contaminated sediments from the channel. In effect this will remove approximately 37,400 kg (82,400 lbs) of PCBs from the ecosystem. However, this could present the potential adverse effects from disposal practices involving multiple upland containment sites. 4-a HONS 009914 Lc. Secondary Impact# the no-action alternative will have several adverse secondary impacts. The continued contamination of Hudson River fishes and the partial closing of tha fisheries will cause a continued loss of income and employment for the region that would occur if the consoercial fishery were fully opened. Closure of the recreational fishery in the upper Hudson River also represents a loss of income that would otherwise be generated by the sale of fishing equipment, bait, gaso line snd other expenditures by sportfishermen. The contamination of drinking water supplies with PCBs to unacceptable levels during a flood event will also have adverse secondary impacts under the no-action alternative. The costs of additional water treatment measures, such ss activated carbon filtration, or coats of providing alternative supplies of water, would be an economic burden to coamiunicies or private individuals if such contamination occurs. If dredge spoils from the lower Hudson River cannot be disposed of in the ocean, substantial economic hardship would be imposed on port areas because alternative methods, such as Land disposal, are much more costly. Maintenance dredging in the upper Hudson River could also become much more costly if highly contaianated dredge spoilt must be held in a safe containment facility instead of t usual dredge spoil site. The no-action alternative could have secondary impacts on agriculture if contamination of forage cropa leads Co excessive PCB levels in milk, rendering it unmarketable. This is not a likely impact of this alternative, however, because contamination of forage crops probably will not become worse in the future. PCB levels in milk from the region have not exceeded FDA tolerance limits. The no-action alternative could have adverse secondary impacts on the development of hydroelectric power in the region. Under the no-action alter native, loss of PCBs from remnant deposits would be greatly accelerated if a surging dam were constructed at Fort Edward by NMPC, as discussed in section Z of Alternative Components, Chapter 2. All or some of the remnant deposits 4-9 MOHS 009915 would have to be removed or adequately stabilized before construction of a surging dam. This would represent a possible impediment to the development of hydroelectric power in the Fort Edvard region. ld. Unavoidable Adverse Impacts and Steps to be Taken to Minimize Harm The no-action alternative poses substantial risks to the fishery, to dis posal of dredge spoils from Che estuary, and to public health. The only possible mitigating measure is to control the flow in the upper Hudson River to reduce the resuspension and transport of PCBs. This could be done with very limited effect iveness at the Conklingville Dam and is not recommended for addressing the existing PCB problem in Che Hudson River. le. Contingency Plans In the event Chat a potable water supply were contaminated with PCBs at concantrations greater chan l ug/1 (ppb), a filtration system or alternate sources of water would be necessary. lf. Monitoring Monitoring of the PCB levels in fishes of the upper and lower Hudson River will be necessary to know when to reopen the fishery. Monitoring PCB concentrations in sediments prior to dredging will enable dredging to occur before those concentrations preclude ocean dumping. Monitoring programs must be established during flood conditions to protect water supplies for down-river communities utilizing the Hudson River for municipal water. IB. No-Action Alternative (Assuming That Routine Channel Maintenance Dredging Is Halted Primary and secondary environmental impacts for this scenario of the no-action alternative are similar to those discussed under the no-action alter native, Chapter 4, section I.lA. Table 2-3 indicates that 112,000 kg (247,000 lb) of PCBs would be transported ineo the estuary over 48 years. This can 4-10 HONS 009916 be compered with 82,600 kg (182,000 lb) of PCB transported into the estuary over 33 years for the no-action alternative assuming that maintenance dredging will be continued. Table 2-3 indicates Chat, if routine channel maintenance of the upper Hudson River were to cease, it would take 48 years from the present date for all the PCBs in the upper Hudson River either to flow into the estuary, or to vola tilize. Under this scenario 112,000 kg (247,000 lb) would be carried over the Federal Dam at Troy, and 33,300 kg (73,500 lb) would be volatilized. Both no-action alternatives (with and without routine channel maintenance) have similar impacts, except that it is more likely that an adverse event will occur under the no-action alternative without maintenance dredging. Routine channel maintenance in the upper Hudson River is likely to be halted unless a containment area is available for dredge spoils with concentrations greater than 50 ug/g (ppm) of PCBs. The cessation of maintenance dredging could create a significant economic hardship on upper Hudson River communities because alternative trans portation systems would be more costly. The mitigating measures, contingency plans and monitoring requirements discussed under section I.1A of this chapter would also apply to this no-action alternative. 2. Control of River Flows This alternative was found to be infeasible, as discussed in Chapter 2. 3. In-River Detoxification This alternative was found to be infeasible, as discussed in Chapter 2. 4. Full-Scale Project The full-scale project involves the removal of hot spots by hydraulic or mechanical means, the disposal of the dredge material in the containment area, the in-river stabilization of selected hot spots, and mitigative actions at the 4-11 HONS 009917 remnant deposits. Impacts will occur with each aspect of the full-scale project. To avoid repetition, short-term impacts associated with the various dredging methods that could be used in the full-scale project are discussed in section II of this chapter (.Alternative Components). Similarly, the impacts associated with the containment of the dredge spoils and the remnant deposit alternatives are also discussed in section II. Only the long-term impacts arising from the removal of PCBs from the Hudson River under the full-scale project will be discussed in this section. 4a. Short-term Primary Impacts The primary impacts of the full-scope project are short term impacts related to the dredging methods, remnant deposit actions and other alternative components utilized in the project. These impacts will be discussed in section II of this chapter. 4b. Long-term Impacts Public Health The full-scale project will have beneficial long-term impacts on public health. The quality of drinking water for communities utilizing the Hudson River water will improve. Although the current PCB drinking water guideline (1 ug/1) is presenlcy being met, removal of contaminated sediments will further reduce present concentrations. A corresponding reduction in health risks will follow. Volatilization of PCBs from the river, remnant deposits and other sources will be aignficantly reduced. Direct contact of the public with PCB-contami nated deposits, particularly at the remnant deposits, will be reduced. The risks associated with exposure to PCBs by the public will therefore decrease. As discussed below, removal of PCBs from the Hudson River under the fullscale project will reduce the amount of PCBs available for uptake by fish. A 4-12 HONS 009918 reduction of PCB levels in fish would have a beneficial impact on public health because it would reduced the dietary uptake of PCBs by the public. Fisheries and Aquatic Biota Monitoring by NYSDEC from 1976 to 1980 indicates that PCB levels in Hudson River fish have declined. If the trend continues, it is possible that PCB levels below the FDA tolerance limit of 5 ug/g (5 ppm) could be achieved by the end of the 1980s and that the fishery could eventually be opened completely. However, if contaminated sediments were resuspended by a major flood event, PCB levels could remain high and the fishery would remain closed. Under normal flow conditions, the full-scale project haa the potential to accelerate the decline in PCB levels and the recovery of the fishery. The project also has the potential to reopen the fishery permanently even under future flood conditions. The full scope project may also directly benefit fish populations in the Hudson River. There is limited evidence indicating that PCB-contamination has adverse effects on the survival and reproduction of certain fish species, including striped bass. The endangered shortnose sturgeon could benefit by a reduction of PCB contamination in the river. Damage from PCBs has been linked to susceptibility of the shortnose sturgeon popoulation to fin rot disease. Some PCB hot spots are in wetlands and their removal would have adverse effaces on food chain relationship# and breeding habitats. Several wetland areas containing hot spots may be affected if these areas are diked or stabilized in place. This action may initiate a succasaion of the vegetation from shallow to deeper rooted plants, thus changing the aquatic and terrestrial fauna. Removal of PCB-contaminattd sediments would have the favorable impact of reducing the bioaccumulation of PCBa through the wetland food web. Agriculture and Terrestrial Biota Under the full-scale project, removal of PCBs from the river bed and banks will decrease volatilization and Che resulting contamination of adjacent terres- A-13 HONS 009919 trial flora, including forage crops. Contamination of forage crops represents a potential risk to the dairy industry because PCBs tend to concentrate in cows and milk. The full-scale project will decrease this risk. A reduction in volatilization will also decrease Che extent of biomagnificacion of PCBs through terrestrial food chains. Maintenance Dredging and Navigation The full-scale project will result in an overall beneficial impact on maintenance dredging and navigation. In the upper Hudson River, continued maintenance dredging will be asaured if concentrationa in dredged material can be reduced to less than SO ug/g (ppm). A piecemeal approach to the disposal of dredge spoils from maintenance dredging will be prevented by providing secure and localized containment for a substantial portion of contaminated sediments. Continued maintenance dredging will also ensure that future navigation is maintained in the upper Hudson River. The full-scale project will also reduce the chance that the PCB content of sediments in the lower Hudson River, especially in the Albany turning basin, will increase to levels that would require upland containment of dredge spoils. 4c. Secondary Impacts The full-scale project will have beneficial secondary impacts. The project has the potential to reduce PCB contamination of Hudson River fish and to hasten the complete reopening of the fisheries. Complete reopening of the commercial and recreational fisharies would have significant economic benefits by creating additional employment and income for residents and businesses of the area. The full-scale project will also have the beneficial impact of enauring that maintenance dredging will not be halted because of excessive contamination of sediments in the upper Hudson River. The economic hardships that would occcur if segments of the river system presently used for barge and other boat traffic btcame unnavigable would not occur. In addition, the economic hardships that could result from a halt of ocean disposal of dredge spoils from Che Lower Hudson River may also be avoided. 4-14 HONS 009920 The full-scale project will facilitate the construction of a hydroelectric dam at Fort Edward. The costs of removing the remnant deposits will no longer be an impediment to construction of the dam and development of hydro electric power. 4d. Unavoidable Adverse Impacts and Steps to be Taken to Minimise Harm Except for the maintenance of a containment facility for dredge spoils, the long-term impacts of the full-scale project will be mainly beneficial and mitigating measures are not needed. If valuable wetlands are destroyed by removal or containment of hot spots, however, a mitigating measure would be the restoration of the wetland. Restoration of a wetland through the planting of wetland vegetation and other reconstruction measures would be especially im portant if the wetland is a valuable wildlife habitat or breeding and nesting area for waterfowl. Mitigating measures applicable to the construction and operation of a con tainment facility are discuased under Alternative Components, section 11.4. of this chapter. Mitigating measures for the adverse impacts of the dredging components will also be discussed in section II, as will the mitigating measures associated with the remnant deposit alternative. 4e. Contingency Plans The full-scale project will substantially reduce the risk that drinking water supplies derived directly or indirectly from the Hudson River could become contaminated by PCBa after a major flood. However, contingency plana should provide for alternate supplies of water or adequate purification systems for residents if PCB levels were to exceed acceptable limits in water supplies. Contingency plana for the operation of a containment facility for the dredge spoils will be discuased in section II of this chapter. Short-term con tingency plena for the dredging and remnant deposit components of the full-seele project will also be discussed in section II. 4-15 HONS 009921 4f. Monitoring Extensive monitoring will be required during the construction and operation of the containment facility (section II, Chapter 4). Long-term monitoring of river water for PCBs and heavy metals must be per formed downstream of removed hot spots to determine the effectiveness of the removal operation. PCB levels in vegetation adjacent to the upper Hudson River, particularly near dams and locks, should also be monitored at least at yearly intervals. Particular attention should be given to forage crops. PCB levels in Hudson River fish must also be monitored to determine if PCB levels have declined enough to permit the reopening of the fishery. 5. Reduced-Scale Project The reduced-scale project involves the removal of selected hot spots by hydraulic or mechanical means, the disposal of the dredge spoils in the contain ment area, and mitigacive actions at the remnant deposits. To avoid repetition, short-term impacts associated with the various dredging components that could be used in the reduced-scale project are discussed in section II of this chapter. Similarly, the impacts associated with the containment of the dredge spoils and the remnant deposit alternative are also discussed in section II. 5a. Short-term Primary Impacts The short-term primary impacts of the reduced-scale project arc impacts related to the dredging methods, remnant deposit actions and ocher alternative components utilized in the project. These impacts will be discussed in section II of this chapter. 5b. Long-term Primary Impacts The long-term impacts associated wieh removal of contaminated sediments from the upper Hudson River under the reduced-scale project are essentially the same ea those of the full-scale project. The reduced scale project will have beneficial impacts on public health, fisheries and aquatic biota, agriculture 6:A-17 4-16 HUNS 009922 and terrestrial biota, and maintenance dredging and navigation. However, the magnitude of these impacts will be less under the reduced-scale project because the amount of contaminated sediment removed from the river system will be less. The long-term adverse impact on wetlands discussed under the full-scale project will not occur under the reduced-scale project. Under the reduced-scale project, hot spots in valuable wetlands will not be removed. 3c. Secondary Impacts The reduced-scale project will have beneficial economic impacts associated with the Hudson River fisheries, maintenance dredging, and ocean disposal of dredge spoils. The secondary impacts of the reduced-scale project will be essentially the same as chose for the full-scale project (section 1.4 of this chapter). The magnitude of the impacts, however, will not be as large because the amount of PCBs removed from Che river system will be less under the reducedscale project. 3d. Unavoidable Adverse Impacts and Steps to be Taken to Minimize Harm. Mitigating measures for the reduced-scale project are the same as those for the full-scale project, with the exception that restoration of wetlands will not be necessary since the reduced-scale project would avoid dredging of the wetland hot spots. 5e. Contingency Plans Contingency plana for the reduced-scale project are the same as chose for th* full-scale project. 5f. Monitoring The monitoring program for the reduced-scale project will be identical to that for the full-scale project. 4-17 MOHS 009923 6. Bsnk-to-Bank Dredging This alternative was found to be infeasible, as discussed in Chapter 2. II. ALTERNATIVE COMPONENTS 1. In-River Containment The in-river containment alternative involves isolation of selected hoe spots with dikes, bulkheads and backfilling. The purpose of in-river con tainment is to prevent erosion of the hot spots and reduce the release of PCBs to the river. 1A. Short-term Primary Impacts Public Health The in-river containment alternative will expose workers at the work site to potential health risks. Air concentrations of PCBs at the hot spots could be greater than 1 ug/cu m, the NIOSH 8-hour recommendation, but well below Che 500 ug/cu m OSHA standard. The health effects of exposure to airborne PCBs are dis cussed in Appendix A. Short-term health risks could be imposed on the public if construction activities cause an increase in releases of PCBs to the air or water. Releases of PCBs are likely to occur through the following processes: Construction of containment structures such as dikes will require dredg ing of PCB-laden sediments in order to prepare a firm substrate as a base. The dredged sediments oust be either transplanted to the in-river contained area or to an upland containment site. Dredging will resuspend sediments and cause release of PCBs to the river and air. The impacts of dredging are discussed in section II.3 of this chapter. Erosion and scouring of PCB-contaminated sediments could increase during the construction phase because vegetation and sediments will be disrupted 4-id MGNS 009924 by machinery, boat movements and other construction activities. Other construction related activities, such as the movement of tug boats in shallow water, will resuspend sediments and PCSs. During the construction phase, volatilization of PCBs will increase as previously buried hot spot sediments are exposed to the air or water. Releases of PCBs to the water and air from construction should be low and of short duration, so public health effects should be minimal. The construction equipment required for in-river containment will create substantial noise that may disturb nearby residential areas. The equipment will also produce minor amounts of air pollution. These impacts will be of short duration and should not create any significant public health problems. Fisheries and Aquatic Biota Releases of PCBs to the river from construction activi will make the contaminment available for accumulation by fish. Because the releases are ex pected to be small and of short duration, the effects on fish of in-river con tainment should not be significant. Benthic organisms in close proximity to construction sctivity, however, may be harmed or killed by local siltation. Existing wetland vegetation and wildlife habitats at and adjacent to areas where containment structures sre to be pieced will be destroyed. Agriculture end Terrestrial Biota The construction equipment will create substantial noise and disrupt nearby wildlife hebitats. Such impacts will be localized and of short duration. No short-term impacts on agriculture are expected from in-river containment of hot spots. 4-19 HONS 009925 Maintenance Dredging and Navigation Barges, boats and other equipment needed in construction activities will ereste a hinderance to normal traffic on the river. Siltation and erosion patterns in the river will be altered in the vicinity of the contained area. Placement of containment structures could hinder navigation on the river. IB. Long-term Primary Impacts Public Health In the long term, in-river containment will stabilize hot spots and prevent erosion of PCB-contaminated sediments. In-river containment will also minimize the release of contaminated material from ice rafting. Decreases in PCB releases will decrease the health risks associated with PCB-contamination of the Hudson River. However, health risks could reoccur if containment of hot spots fails. Major damage to containment structures could occur from high flow periods, ice jama, or boat collisions. Cradual weakening of containment structures could arise from normal, long-term river proceases. Fisheries and Aquatic Biota In-river containment will benefit the fisheries in the long-term because it a will decrease the amount of PCBs readily available for uptake in aquatic eco systems. This could help to reduce the PCB content of fish to levels below the acceptable tolerance limit. A failure of the containment structures, however, would cause the release of PCBs to the aquatic ecosystem. In-river containment will have long-term impacts on contained wetlands. Silt transported in runoff from the land will accumulate in the contained areas, covering PCB-leden sediments. This will have the beneficial impact of stabi lizing the contained area and encouraging the growth of more deeply rooted vegetation. This process will further stabilize the hot spot and decrease volatilization of PCBs. Containment of wetland hot spots will substantially alter drainage patterns within the wetland. This may have adverse effects on the nature of ehe vege- 4-20 HONS 009926 Cation and wildlife habitat. Containment will reduce the exchange of water, causing greater extremes in temperature of contained surface waters. Reduced circulation will also decrease oxygen levels of contained surface waters, par ticularly during warm weather. The value of the wetland as a wildlife habitat will probably decrease. Containment, stabilization and backfilling of presently shallow hot spots may create additional wetlands. This would have the beneficial impact of creat ing new wildlife habitats in the river system. Agriculture and Terrestrial Biota In-river containment will reduce volatilization of PCBs and therefore reduce the amount of PCBs availabe for uptake by terrestrial ecosystems. This beneficial impact, however, may not be large because only a small number of hot spota are suitable for in-river containment under the full-scale project. Maintenance Dredging and Navigation By stabilizing PCB hot apota, in-river containment will help prevent further contamination of down-river sediments. This will help prevent PCB levels from reaching such high levels that dredge spoils from maintenance dredging would require costly upland containment. Siltation and erosion patterns in the river would be altered in the vicinity of the contained area, possibly creating navigational problems. Placement of containment structures could hinder navigation on the river. 1C. Secondary Impacts Because in-river containment will help to reduce the release of PCBs from hot spots to the river system, the in-river containment alternative will have beneficial effects, with corresponding beneficial secondary impacts, on the fisheries, maintenance dredging in the upper Hudson River and ocean disposal of 4-21 HONS 009927 dredge poil from Che lover Hudson River. Secondary impacts of this alternative will be similar in nature to chose that will occur from removal of hots spots, as described in seecion 1.4 of this chapter (full-scale project). the secondary impacts attributable to in-river containment of hot spots, however, will not be large because only a small number of hot spots are suitable for in-river con tainment . ID. Unavoidable Adverse Impacts and Steps to be Taken to Mininize Harm Unavoidable adverse impacts can be mnimized by implementing the following measures: All work on the hot spots should be performed during the dry season, between May and September. Low rainfall and low flows will minimize erosion and scouring, and decrease chances of flood flows occurring while the work is still incomplete, thus minimizing release of PCBs to the river. a Only vegetation that poses a direct hindrance or hazard to work on the hot spots should be removed. Protective clothing, including respirators, should be provided workers at the site to minimize health risks. to ail The public should not have access to the hot spots and surrounding area during the work phase. Work which generates excessive noise should only be conducted during normal working hours to minimize disturbance to the public. Public access to contained hoc spots should be discouraged by posting of warning signs. If feasible, access should be prevented by placement of fences. e Hot spots should be cqvered to a height above the 100- or 500-year flood level to reduce the risk of erosion during major flood events. However, this would eliminate the wetland character of the hot spot. 4-22 MGNS 009926 IE. Contingency Plans Major damage to the containment structures may occur during high flow periods, ice jama, or boat collisions. If containment structures are damaged, repair would have to be made immediately. NYSDEC will have the authority to make arrangements for immediate repairs. Contingency plans discussed under the full-scale project (section 4, Chapter 4 ) should also apply under this alternative. IF. Monitoring Short-term monitoring should accompany construction of the contaimene structures and consist of air and water sampling. Water sampling for turbidity, Cs , lead and PCBs should be done at regular intervals downstream of con struction activity. Air quality should be sampled everyday at four locations representing the major compass directions. Long-term monitoring will consist of periodic water and air sampling. Water samples should be taken downstream of each in-river contained hot spot and should be analyzed for PCBs and heavy metals. Samples should be taken once every two months. Air samples should be taken and analyzed for PCBs, Additionally, samples of the vegetation should be analyzed for PCB levels once every year. 2. Remnant Deposit Alternatives After the dam at Fort Edward was removed in 1973 , most of the contaminated sediment originally contained behind the dam that was not transported down stream remained as exposed deposits along the river bank at five locations. Of these five remnant deposit areas only two, deposits 3 and 5, are presently con sidered to be a significant source of PCB to the environment. The most highly contaminated remnant area, 3A, was removed to the new Moreau NYSDOT site in 1978. 2A. Remnant Deposit No-Action Alternative 2a. Short-term Primary Impacts Under the no-action remnant deposit alternative, there will not be adverse 4-23 HONS 009929 primary impacts because the PCB-contaminated deposits will not be removed or contained. No-action would permit the continued release of PCBs from the remnent deposits. Such PCB releases could present long-term adverse impacts, as de scribed below. The beneficial primary impacts of no-action include the avoidance of short term construction related effects such as noise, truck traffic, and ocher disrup tions to the public. 2b. Secondary Impacts Public Health Under the remnant deposit no-action alternative, the main long-term impact will be the continued release of PCBs to the Hudson River and surrounding air and ehe public health risks associated with PCB contamination of the Hudson River. The amount of PCBs being released from the remnant deposits to the Hudson, however, has not been adequately determined. There is a subatantial flow of PCBa, 590 to 1315 kg/yr (1300 to 2900 lbs/yr), in the Hudson River at Rogers Island (MPL, 1980d). The source of this flow has not been identified, and it has not been determined to whet extent Che remnant deposits are contributing to this flow. As discussed in section II.2 of Chapter 2, deposits 1,2,3 and 4A ere subject to erosion, especially during high flows. These deposits, however, contain relatively low levels and small total amounts of PCBs (Tables 2-8a and 2-8b). Remnant deposits 3 and 5 contain high concentrations and substantial total amounts of PCBs, but remedial measures have been taken to stabilize them. Under the no-action alternative, the short-term impacts of the remnant deposits on water quality and public health cannot be fully assessed until the unknown source of PCBa in the upper Hudson River is determined and the stability of deposits 3 and 5 is confirmed. Under the no-action alternative, continued release of PCB through volati lization is also a potential health risk. The remnant deposits, especially those on the east side of the river, are in fairly close proximity to residential areas. Some of the remnant deposits are accessible by the public, creating an 4-24 HONS 009930 additional risk to public health. re discussed in Appendix A. The health hazards of exposure to PCB in air A potential long-term impact of the remnant no-sction sltsrnstive is the relesse of lsrge quantities of PCBs if the deposits undergo extensive erosion during s high flow period, as occurred in 1976. Erosion of deposits 1,2, 4 and 4A is possible during high flows because little or no stabilization measures have been taken on them. Erosion of these deposits would not have a great impact because they do not contain large quantities of PCBs. Erosion of deposits 3 and 5 would release substantial quantities of PCB to the Hudson River, causing a substantial reduction in water quality, increased contamination of fish and other biota, the formation of new hot spots in downstream areas of deposition, and risks to public health. The chances of large scale erosion of deposits 3 and 5, however, are not great because stabilization measures, including rip-rapping, have bean taken. Fisheries and Aquatic Biota The continued release of PCBs from remnant deposits could make substantial amounts of the contaminant available for uptake by the aquatic ecosystem. Such releases, depending on their magnitude, may be contributing to the PCB contami nation of Hudson River fish. The remnant deposit no-action alternative may lengthen the time required for fish PCB levels to decrease to levels low enough for Che fishery to be reopened. Agriculture and Terrestrial Biota Under the remnant deposit no-action alternative, volatilization of PCBs from eha remnant deposits, estimated co be 130 kg (280 lb), will continue, causing locally reduced air quality and contamination of adjacent vegetation. Agricultural products grown within 700 m (2300 ft) of remnant deposits may have PCB concentrations above background levels. Volatilization from remnant de posits represents a route by which PCBs can enter terrestrial ecosystems and bioaccumulate in exposed organisms. 4-25 HONS 009931 Maintenance Dredging and Navigation The no-action alternative does not provide protection against large-scale scouring of remnant deposits during future flood events. Such scouring could lead to the formation of new PCB hot spots in the river, impairing the ability to dispose of dredge spoils from the upper and lower Hudson River. Large-scale erosion of remnant deposits with the consequential release of PCBs to the river could contribute to PCB contamination of downstream sediments. As discussed in section 1.1 of Chapter IV (No-Action Alternative), sediments could become contaminated with PCBs to such an extent that spoils from maintenance dredging could no longer be disposed of in usual manners, eventually resulting in a halt to maintenance dredging and closing of some navigational channels. Although long-term impacts under the no-ection remnant deposit alternative would most likely not be as great as those associated with large-scale movement of hot spot sediments, they could be significant because of the large quantity of PCBs prasently contained in the remnant deposits. 2c. Secondary Impacts The no-action remnant deposit alternative may have adverse secondary impacts similar to those discussed for the no-ection alternative (section 1.1 of this chapter). The potential large-scale release of PCBs from the remnant deposits to the Hudson River could have adverse economic impacts associated with the con tinued closure of the fisheries, the contamination of downstream water supplies, end the halting of maintenance dredging. Adverse secondary impacts are less likely to result from the remnant deposits than from PCB hot spots in the river because the remnant deposits are more stable and less subject to scour than the hots spots. In addition, there are less PCBs contained in the remnant deposits than in all the hot spots. Volatilization of PCBs from remnant deposits could contaminets nearby agricultural crops, especially private garden crops, with unacceptable amounts of PCBs. This would cause an economic loss to farmers or garden owners if their crops became unmarketable or inedible. 4-26 HONS 009932  The no~action remnant deposit alternative would also have secondary impacts on hydroelectric power generation at Fort Edward. If the NMPC constructed a surging dam for the generation of electric power at the old Fort Edward dam site, as the company has proposed, the remnant deposits would be resubmerged, and release of PCBs to the river would be accelerated. Therefore, the remnant deposits would have to be removed or effectively stabilized before construction of the dam. This would represent a possible impediment for development of ehe dam and hydroelectric power. 2d. Unavoidable Adverse Impacts and Steps to be Taken to Minimize Harm Control of river flow by the Conkiingville Dam would prevent scouring of the remnant deposits during a flood event. As discussed in section 1.1 of Chapter IV, the dam has very limited potential for such use. No other mitigative measures are considered under the remnant deposit no-action alternative. 2e. Contingency Plans Contingency plans are necessary if a future flood event causes further destabilization of remnant deposits and substantial loss of PCBs to the river. Measures should be taken to re-establish stability and prevent unrestrained scouring of the deposits, especially deposits 3 and 3, through bank reinforce ment and other erosion control measures. Contingency plans must provide for the protection of public health if scouring of remnant deposits sharply increase PCB levels in the river. Such an increase poses a potential threat to downstream fishery resources and public drinking water supplies. The same contingency plans that apply under the no-action alternative, discussed in section l.l of Chapter IV, should also apply to the remnant deposit no-action alternative. 2f. Monitoring Monitoring of PCB lvel in water undar the remnant dapoait no-action alternative must be conducted so that any changes in the amounts of PCBs flowing 4-2 7 MQNS 009933 downstream at Fort Edward can be detected. Such an increase could indicate that deatabilizAtion of remnant deposits has occurred. Monitoring of water PC 8 levels must be intensified during and several weeks after any significant high flow events. In addition to the monitoring program, a careful sampling program must be initiated as soon as possible in the upper Hudson River to identify the present ly unknown source of PCBs above Fort Edward. Series of water samples should be taken starting at Rogers Island and extending upstream several miles. Samples should be taken over a range of seasonal and flow conditions. If PCBs are entering the river from a fairly concentrated source, such as an undiscovered landfill, wastewater discharge, or the remnant deposits, PCB levels should decrease fsirly abruptly upstream of the vicinity of the input. Absence of such a drop in PCB levels would indicate the existence of a source of PCBs further upriver or non-point sources. Confirmation of whether or not the remnant de posits are presently a- substantial source of PCB contamination of the Hudson River is critical for determining the proper course of action for the remnant deposites and for determining the relative priorities of dredging lower river hot pots and removing remnant deposits. Monitoring of PCB levels in air around the remnant deposits and around residential areas nearest the deposits should also be undertaken. Monitoring should be done under various seasonal and meteorological conditions so that PCB levels under worst case conditions can be assessed. 2B. Penial of Access 2a. Short-term Primary Impacts The denial of access alternative will have impacts related to construction activities. Because this alternative only involves limited constuccion activity (erection of fences, placement of warning signs and seeding of bare ground), these impacts should be minor. 4-28 HONS 009934 Public Health The denial of access alternative will impose a slight health risk to workers implementing the actions of the alternative. Air concentrations of PCBs at the remnant deposits could be over 1 ug/cu m, the NIOSH 8-hour recom mendation, but well below che 500 ug/cu m OSHA standard. The health effects of exposure to airborne PCBs are discussed in Appendix A. Materials will have to be trucked to the sites through residential neigh borhoods, causing slight disruption to inhabitants. Because the amount of materials needed is not large, such impacts will be small and for a short duration. There will be noise impacts from the machinery needed to implant the fences. Noise impacts should not be great because heavy machinery is not needed and the duration of activity wilL be short. Fisheries and Aquatic Biota This alternative may have slight impacts on aquatic biota by causing small releases of PCBs to Che Hudson River during the construction phase. The removal of vegetation in the path of the fence and the digging of a trench and post holes for emplacement of the fence may increase erosion and cause slight increases in PC8 losses to the river. The increases should not be large enough to affect fish or other aquatic biota. Agriculture and Terrestrial Biota This alternative will have no primary impacts on agriculture. construction activities may disturb local fauna. Noise from Maintenance Dred^tng and Navigation This alternative will have no short-term primary impacts on maintenance dredging and navigation. 4-29 MGN5 009935 2b. long-term Primary Impacts Th denial of access alternative will have the same adverse long-term impacts as described for the remnant deposit no-action alternative (section I1.2A of this chapter) because this alternative has no provisions for stabi lisation or removal of remnant deposit material. The denial of access alter native, however, will have an additional beneficial impact on public health. Public health risks will be slightly reduced because people will no longer have access to the deposits, thus eliminating direct exposure to the contaminated material. 2c. Secondary Impacts The adverse secondary impacts that could occur under this alternative are the same as those discussed for the remnant deposit no-action alternative (section II.2A. of this chapter). 2d. Unavoidable Adverse Impacts and Steps to be Taken to Minimize Harm Mitigating measures that should be taken to minimize unavoidable adverse impacts are described below. Reseeding of all disrupted soils should be undertaken as quickly as possible to establish a vegetative cover and prevent erosion. Work should be carried outduring the dry season so that chances of rainfall are minimised, thus decreasing the potential for erosion of distrubed soils. River flows will also be lowest during the dry season, thus diminishing chances of flood flows that could easily erode dis turbed soils. . Work and trucking of materials should be done during working, daytime hours as much as possible to minimize inconvenience and disturbance for nearby residential areas. 4-30 HONS 009936  Protective clothing, including respirators, should be provided to workers on the site to minimize their health risks. 2e. Contingency Plans Because the denial of access alternative does not stabilise the remnant deposits, the contingency plans discussed under the remnant-deposit no-action plan also apply to this alternative. These plans include the restabilization of the deposits in the event they are scoured by a flood event, and plans to safe guard health of the public if enough scouring of deposits and release of PCBs occur to threaten downriver drinking water supplies and fishery resources. 2f. Monitoring The monitoring described under the remnant deposit no-action plan should also be applied to this alternative. 2C. Remnant Deposit In-Place Containment 2a. Short-term Primary Impacts The in-place containment alternative involves the stabilization of remnant deposits by placement of an impermeable cover and by reinforcement of the river bank. The short-term primary impacts are related to construction activities. Public Health The in-place containment alternative could expose workers at the work site to health risks. Air concentrations of PCB at the remnant deposits could exceed 1 ug/cu m, which is the recommended NIOSH 8-hour standard, but will be well below Che 500 ug/cu m OSHA standard. The health effects of exposure to airborne PCBs are discussed in Appendix A. Short-term health threats could be imposed on the public if construction activities cause an increase in releases of PCBs to air or water during the cons 4-31 HONS 009937 truction phase. Such releases should be low and of short duration, so health effects should be minimal. Trucking of materials to the remnant deposits will cause severe disruption of residential areas near the remnant deposits because of the noise, traffic and air pollution chat will result. The transport of materials needed for in-place containment of deposits 3 and 5 will require 5,000 to 10,000 truck trips, de pending on truck capacities (MPl, 1980d). Noise and air pollution created by the machinery needed at the work sites will also disrupt nearby residents. In-place containment would also preclude the removal of the contaminated materiel which would release significant quantities of PCBs to the eir end water during excavation. Also there would be an increase in the number of truck trips for removal. Fisheries and Aquatic Biota Destruction of vegetation and disruption of soils during the construction phase could temporarily increase erosion and destabilize river banks, conse quently increasing loss of PCBs to the river. The impacts of such PC8 losses to the water should not be large. Agriculture and Terrestrial Biota In-place containment of remnant deposits will have no significant short term impacts on agriculture. Noise from construction activities may distrub local fauna. In addition, existing vegetation on and adjacent to the remnant deposits and the paths of needed access roads will be destroyed. Maintenance Dredging and Navigation In-place containment of remnant deposits will have no significant short term impacts on maintenance dredging and agriculture. 2b. Long-term Primary Impacts 4-32 HONS 009938 Public Health Stabilization and cover of remnant deposits would decrease public health risks by reducing volatilization of PCBs to the air and by reducing any present losses of PCBs to the river. In the long term, however, any failure of the containment measures could result in releases of PCBs to the environment and a reoccurrence of public health risks. Health effects of exposure to PCBs to the public are discussed in Appendix A. Because PCBs are not removed from the river system under this alternative, any long-term erosional patterns of the river could weaken containment measures and cause PCB contamination of the river. Continuous maintenance of the cover and bank reinforcements would be necessary to minimize this threat. Fisheries and Aquatic Biota In-place containment of the remnant deposits would decrease risks to the fisheries by reducing PCB losses to the Hudson River by erosion and other pro cesses. However, if containment of remnant deposits failed and PCB-contami nated sediments were released to the river, risks to the fishery would reoccur. Maintenance Dredging and Terrestrial Biota Containment of remnant deposits will decrease the amounts of PCBs entering sediments of the Hudson River. This would partially prevent dredge spoils resulting from maintenance dredging ot the upper Hudson River from becoming too contaminated with PCBa to be disposed of in usual manners. The chances of lower Hudson River sediments becoming too contaminated for ocean disposal also may be reduced. 2c. Secondary Impacts In-place containment of remnant depoaits will reduce PCB contamination of the Hudaon River, and help to avoid the adverse secondary impacts that could ariae from the continued closure of the fisheries, the halting of maintenance dredging and the ocean disposal of dredge spoils, and the contamination of 4-33 HONS 009939 downstream drinking water supplies, as discussed under the remnant deposit no-sction alternative (section II.2A of this chapter). In-place containment of remnant deposits, however, may not adequately stabilize the deposits if a surging dam is constructed at Fort Edward. The costs of additional stabilization methods or removal of the deposits could be an impediment to development of the dam and hydroelectric power at Fort Edward. 2d. Unavoidable Adverse Impacts and Steps to be Taken to Minimize Harm Unavoidable adverse impacts can be minimized by implementing the following measures for the in-place containment of remnant deposits: To control erosion, all work on the remnant deposits should be performed during the dry season, between May and September. Low rainfall and low flows will minimize erosion of disturbed soils and decreaae chances of flood flows occurring while the work is still incomplete, thus minimizing release of PCBs to the river. Disturbed soils should be reseeded as quickly as possible to stabilize soils and prevent erosion. Only vegeta tion that poses s direct hindrance or hazard to work on the remnant deposits and access roads should be removed. To minimize the risk of eroding the remnant deposits during floods, the cover should be brought to a grade level above either the 100 or 500-year flood level. Protective clothing, including respirators, should be provided to all worker* it the site to minimize health risks for them. The public should not have access to the remnant deposits during the work phase. To reduce noise impacts, mufflers and engines should be properly main tained to minimize noise levels, with the use of additional mufflers, 4-34 HONS 009940 silencers, end/or baffle structures as necessary. Work performed near homes which generates especially loud noise should be scheduled within normal working hours. Night work should be minimized to the greatest extent possible (MPI, 1980d). e The contractor should not wash vehicles, change engine oil, or repair hydraulic lines near the working area or the river. Petroleum compounds must not leak into the deposit areas or directly into the river because such compounds will desorb PCBs from debris and sediments. In addition, all vehicles should be well maintained to minimize exhaust emissions (MPI, 1980d). e Trucks enroute to the work area carrying uncontaminated sediments should have their cargo covered, as required by Section 380-a, Chapter 418 of the Laws of 1975, and 17 NYCRR Part 158 (MPI, 1980d). Paved roads used by construction traffic should be kept in a broomcleaned condition to minimize wind-blown dust. If fugitive dust becomes a problem at remnant deposits or access roads, a light spray of water or other appropriate agent should be epplied (MPI, 1980d). e Signs,warning lights and/or flagmen should be employed along routes wherehesvy truck traffic is anticipated, particularly at busy inter sections. Roads which are damaged by truck activity should be repaired to at least their original condition (MPI, 1980d). Whenthe project has been completed, the area should belandscaped, including the planting of trees, to make the area visually attractive. 2e. Contingency Plans A contingency plan must be established to re-$cabilize the remnant depoaits if containment measures fail. If a flood event erodes the capping layer on a remnant deposit and PCB-laden sediments begin to escape to the river, measures tsust be taken as soon as possible to repair the situation. 4-35 HONS 009941 There muse aLso be contingency plans Co safeguard public healeh if contain ment docs fail and Large quantities of remnant deposit materials are washed into the Hudson River during a flood or other unusual event. Measures would have to be taken to ensure the public would be protected from increases of PCB levels in downstream areas of the Hudson River. Contingency plans similar to those discussed for the remnant deposit no-action alternative (section II.2A, Chapter 4 ) would be required. 2f. Monitoring Under the in-place containment alternative, PCB levels in water downstreme of the remnant deposits will have to be monitored. PCB levels will have to be monitored frequently in areas several hundred yards downstream of the remnant deposits when construction is in process to ensure that the activity does not cause a significant release of PCBs to the river. Levels of PCBs in the air should also be monitored at the worksite and also in nearby residential areas to ensure that PCB levels do not increase above acceptable levels while the work is in process. Long-term monitoring of PCB levels in the water downstream of the remnant deposits and in vegetation adjacent to remnant deposits is necessary to make certain that containment is effective. 2D. Remnant Deposit Complete and Partial Removal A complete or partial removal of remnant deposits will mainly have short term primary impacts directly related to the excavation and hauling away of remnant deposit material. Complete and partial removal alternatives would have similar impacts. Complete removal would have impacts of greater magnitude and longer duration. The long-term impacts of remnant deposit removal are bene ficial . Under the complete removal alternative, 290,000 cu m (380,000 cu yds) of remnant deposit material would have to be removed, requiring approximately 40,000 truck trips, as discussed in Section II.2 of Chapter 2 . Removal of 4-36 HONS 009942 deposits 3 snd 5, ss proposed by NYSDEC, would involve 36,000 cu m (73,400 cu yd) snd 7,400 truck trips (MPI, 198Gd). Under partial removal plans, remnant deposits which are not removed could be contained in-place as described in section 11.2 of Chapter 2. Impacts of in place containment of remnant deposits are discussed in section II.2 of Chapter 4. 2a. Short-term Primary Impacts Pubic Health Removal of remnant deposits will have adverse short-term impacts on public health. During the removal process, health risks will be imposed on workers. Ex* cavating the deposits will temporarily increase volatilization and levels of PCB in the air at and around the work site. Air concentrations of PCBs could be over 1 ug/cu m, the NIOSH 8-hour recommendation, but well below the 500 ug/cu m OSHA standard (MPI, 1980d). The health effects of exposure to airborne PCBs are discussed in Appendix A. Excavation of remnant deposits will increase volatilizatin of PCBs, in creasing contamination of surrounding vegetation and imposing health risks on nearby residents. During dry or windy conditions, PCB-laden particles will be lost to the air. The earth moving equipment will create substantial noise pollution and contribute to local air pollution in nearby residential areas. Noise, traffic congestion and air pollution resulting from the large number of truck trips needed to remove contaminated material will severely disrupt residential areaa in Fort Edward. Trucking of contaminated materials away from the remnant deposits creates the potential for contamination of roads and road side areas if proper containment procedures are not followed on every truck trip. 4-37 MONS 009943 The public health implications of upland disposal of PCB contaminated materials are discueaed in section II.4 of this chapter. Removal of the remnant deposit material nearest the river will result in resuspension of PCB-contaminated materials and their loss to the river. Destruction of vegetation and disruption of soils at and around the remnant deposits will temporarily increase erosion of PCB-contaminated material into the river. Such releases of PCBs to the river will be small and of short duration, and impacts on Che fish and other aquatic biota should be minimal. Agriculture and Terrestrial Biota Vegetation at and adjacent to the remnant deposits and the paths of needed access roads will be destroyed. Noise from trucks and escavation equipment will disturb fauns in the vicinity of the remnant deposits and trucking routes. Increased volatilization of PCBs during escavation may slightly increase con tamination of adjacent vegetation. Removal of remnant deposits will not have significant short-term impacts on agriculture. Maintenance Dredging and Navigation Removal of the remnant deposits will have no significant short-term impacts on maintenance dredging and navigation. 2b. Long-term Primary Impacts Public Health Removal of remnant deposits will have beneficial long-term impacts. Re moval will significantly decrease potential health threats by stopping PCB losses from the deposits to the air and river. This will be especially signi ficant if Che remnant deposit# are the presently unidentified source of PCBs in the Hudson River. The public health risks of exposure to PCBs in water, food and air are discussed in Appendix A. Removal of remnant deposits will also eliminate the chance that future erosion, particularly during a flood event, could release large quantities of contaminated remnant deposit material to the river. 4-38 MOWS 009944 Fisheries and Aquatic Biota Removal of remnant deposits will reduce the amount of PCBs entering the Hudson River. Removal will also eliminate the chance that future erosion during a flood event could release large quantities of PCBs to the river. Elimination of this source of PCBs will partially reduce PCB-contsmination of Hudson River fish. Agriculture and Terrestrial Biota Removal of remnant deposits will substantially reduce volatilisation of PCBs and therefore reduce contamination of nearby vegetation, including agri cultural crops. This will eliminate a possible pathway for PCBs to enter terrestrial food chains and bioaccumulate in terrestrial fauna. Maintenance Dredging and Navigation The beneficial impact of remnant site removal will be the elimination of this particular source of PCBs as a potential constraint on dredging and disposal should these deposits be scoured during a flood and transported down river. 2c. Secondary Impacts Removal of remnant deposits will reduce existing and future PCB releases to the Hudson River, end help to avoid the adverse secondary impacts that could arise from the continued closure of the fisheries, the halting of maintenance dredging and ocean dispoaal of dredge spoils, and the contamination of downstream drinking water supplies, as discussed for the remnant deposit no-action alter native (section II.2A of this chapter). Under the removal alternatives, the remnant deposits will no longer represent s possible impediment to the construction of s hydroelectric dam at Fort Edvard. 2d. Unavoidable Adverse Impacts and Steps to be Taken to Minimize Harm 4-39 HONS 009945 Unavoidable adverse impaces can be minimized by implementing the same measures discussed for the remnant deposit in-place containment alternative (section 11.2c of this chapter). The following measures should also be eaken under this alternative: e Excavation should be done by highly experienced personnel so that the deposits can be removed as quickly, efficiently, and neatly as possible. This will help to reduce risks of any unnecessary losses of contaminants to the air or river. a To prevent loss of material to the river, escavation should begin in the center of the deposit, leaving an outer perimeter of material to act as a protactiva aarthan dike. Should floating solids result from dredging, a floating boom would be employed downstream from the dredge site (MPI, 1980d). a Trucks enrouta to the disposal area should have their cargo covered, aa required by Section 380-a, Chapter 418 of the Laws of 1975, and 17 NYCRR Part 158 (MPI, 1980d). It is imperative that the trucks strictly adhere Co Che regulations and that they be tightly covered. It is also impor tant that they not be overloaded. In addition, the trucks should be cleaned before leaving the containment site to minimize the tracking of contaminated material onto the roadways and into the residential areas. a Completely contained trucks or trailers could be useful if there is the risk of contaminated water running off trucks transporting wet sediment. a The NYSDOH and local authorities, in conjunction with NYSDEC, must carefully oversee all operations of this alternative, particularly the trucking of the contaminated material, to safeguard the safety of the public end workers. State or local police should also be on site and frequently inspect the trucks involved to make sure that they meet motor vehicle safety requirements. 4-40 HOMS 009946 2e. Contingency Plana Contingency plans must provide for public safety in the event that the removal operation causes unacceptably high losses of PCBs to the air or river. Cessation or revision of the operation and evacuation of local residents could be necessary. Contingency plans regarding downstream drinking water supplies in Che event of additional PCB contamination of the river could also apply. 2f. Monitoring Throughout the removal operation, PCB levels downstream of the operation must be frequently monitored so that any significant increase in PCB losses to the river can be detected. Two sampling wells should be installed near each downstream perimeter of the remnant deposit to monitor the movement of PCBs with groundwater through the deposits and into the water column (MPI, 1980d). PCB levels in the air at the worksite and in adjacent residential areas must also be monitored. After the removal operation is complete, PCB levels in the river downstream of the former remnant deposits must also be monitored to ensure that substantial amounts of contaminated deposits were not left behind. Such deposits could continue to release PCBs to the river. 3. In-River Dredging Mechanisms This section of the BIS will discuss the primary environmental impacts of the feasible dredging alternatives avjilable for physically removing PCB contam inated sediments from the Hudson River. In-river dredging mechanisms are components of the full-scale and reduced-scale projects. As a result of exces sive costs and other technical considerations, mechanical unloading of dredge spoils and dredging systems discussed under "Other Dredging Systems" in chapter 2, except for the mud cat, were found co be infeasible and will not be considered further. The mud cat might have limited application in shallow hot spots. Hydraulic dredging and transport, and clamshell dredging with hydraulic pumpout and unloading are the main feasible alternatives, and they will be evaluated for potential adverse and beneficial, short-term environmental impacts. <*-41 HONS 009947 Environmental analysis of the dredging and transport mechanisms will be discussed as they affect the major primary assessment objectives outlined at the beginning of this chapter with special emphasis on the following parameters: a Water Quality e Public Health Fisheries and Aquatic Biota Maintenance Dredging and Navigation The long-term primary impacts and secondary impacts of the full-scale and reduced-scale projects, which include in-river dredging components, in-river containment and remnant deposit alternative components, have already been discussed in Sections 1.4 and 1.5 of this Chapter. 3A. Short-Term Primary Impacts 3a. Hydraulic Dredging Water Quality The most critical environmental factor that may be affected by dredging activities is water quality. The impacts are a result of (1) continued effects of PCBs left in place after dredging; (2) PCBs lost downriver in the dredge plume and (3) PCBs recycled to the river in the return water. The magnitude of these losses, as projected by MPI (1980d), are summarized in Table E-3 (Appendix E). PCB losses to the water column from a hydraulic dredgehead occur when bottom material disturbed by the rotating and laterally moving dredgehead is stirred up but is not drawn into the hydraulic pipeline. MPI (1978b, 1980d) estimates, based on the assumption chat the bed material is predominantly sand and gravel, that 2 percent of the total material dredged will escape to the water column. Laboratory testing conducted by MPI demonstrated that in a suspension approximating a dredge plume, about 20 percent of the PCB does not readily resettle, while the remaining 80 percent would settle downstream from Che dredge. The suspended PCB contaminated sediment may or may not resettle in downstream hot spots and it is possible that 100 percent of the plume could be 4-42 HONS 00994b loet (MPI, 1980d). If a flow of 85 cu m/s (3,000 cfa) is assumed, che estimated average PCB increase above ambient levels immediately downstream of the dredge* head could be 0.2 ug/l (ppb) for the hydraulic dredge. The NYSDEC standard for ambient levels of PCB downstream from a dredging operation is 0.5 ug/l (ppb) (MPI, 1978a). Dredgehead losses from the hydraulic dredge alternative are within this standard (MPI, 1978a). If this standard were exceeded, dredging operations would be stopped. Tofflemire (1979) evaluated the dredgehead losses from a hydraulic dredge and clamshell dredge operating adjacent to each other. The objective was to try to compare Che two types of dredging where all variables were equal. He at* tempted to relate suspended solids, turbidity and PCB losses from the dredge plume. Readings taken 60 m (200 ft) downstream of the hydraulic dredge indi cate very little turbidity and little increase in PCB concentrations in the water column. However the transmissometer used to measure turbidity malfunc tioned and there was difficulty in establishing a correlation between suspended solids and turbidity. Though these problems may have altered the data, the overall conclusion that a dredge plume developed by che hydraulic dredgehead will disperse end resettle within 1.6 km (1 mi) downstream is valid. However, boeh background levels and anticipated increases are several orders of magnitude above the SPA criterion for the protection of freshwater life, which is 1 part per trillion or 0.001 ug/l (MPI, 1978a). In addition Co loss of PCB# in the dredgehead plume, certain amounts will be missed during dredging, due to inherent imprecision in dredge positioning, depth control, end difficulties with obstructions in the river. MPI (1978a, 1980d) estimates that a hydraulic dredge would miss 2 percent of the hot spot material. This includes e dredging pay limit sec at 91 cm (36 in.). Based on the 2 percent loss, it is estimated thee 950 kg (2,100 lbs) will be left in the Thompson Island Pool. However, this estimate for PCBs missed during dredging may be low. Tofflemire (1979) astimaces that hydraulic dredging of PCB hot spots consisting of sediments whose grain size composition averages between 50 to 60 percent silt, will miss 13 percent of the sediments. Factors critical to control of contaminated layer removal are boom swing speed, position of the dredge, amount of overlap, depth of dredge cut, end operator experience. Further evaluation of dredgehead placement end the amount of PCB contaminates materiel missed by the dredgehead is necessary before a full evaluation of impacts is possible. 4-43 MOWS 009949 Under Che hydraulic dredging alternative, Che average return water flow will be 37,800 cu m/d (10 mgd). Thia water is mixed with the dredged material at Che dredgehead and used to transport the sediments by pipeline to the contain ment site. At the containment site, the sediment and water will flow through a series of settling lagoons to produce a nearly sediment-free water. At this point it will enter a water treatment plant to remove suspended particulates with PCBs. The plant will have a capacity of 49,200 cu m/d (13 mgd) and consist of coagulation, flocculation, and sedimentation units. For hydraulic dredging of the Thompson Island Pool, an estimated 70 kg (160 lbs) of PCBs would be lost via the return flow per year. Such a loss would result in an increase above ambient of 0.1 ug/1 (ppb), assuming complete dilution of the effluent in 85 cu m/s (3,000 cfs). As estimated previously, dredgehead losses would raise the ambient PCB levels of 0.2 ug/1 (ppb). The total calculated PCB increase attribut able to Che hydraulic dredge, without carbon absorption, would be 0.3 ug/1 (ppb) (MPI, 1980d). This increase would occur during the 20-hour work day. Background levels measured at Schuylerville and Stillwater during low flow between June and September 1977 averaged approximately 0.7 ug/1 (ppb). While this average may be atypically high, it will be used here as a worst case (MPI, 1978a). The etti- laated PCB increase in combination with the background level would result in a total of PCB concentration of approximately 1.0 ug/1 (ppb). The potential loss of heavy metals to the water column from dredgehead disturbance of the bottom and return flow concentrations is important due to the toxicity of many metals to aquatic life and the effect on down river public water supplies. Such losses are dependent on the efficiency of the dredge, the metal levels encountered in bed materials (Table E-4, Appendix E) and the ability of the return water treatmenc process in removing metals along with the PCBs. The majority of heavy metals in the upper Hudson River ere bound to the organic end fine grained particulate matter. Additionally, metals may also be present in the interstitial water or as part of the crystalline structure. Upon disturbance from the dredgehead, the interstitial component is immediately released to the water columns, while the fraction that ia attached to the particulate matter releases to the water column at various rates, depending upon ambient conditions sueh as pH, redox potential, end the presence of complexing chemicals which 4-44 MONS 009950 would act to precipitate dissolved metals. Because of the diversity of factors affecting the release of heavy metals, it is highly difficult to predict water column interactions (MPI, 1978a). However, a conservative best-estimate is possible based on bed material concentrations. MPI (1978a) has estimated dredgehead losses for hydraulic and clamshell dredging. Using existing information for the Thompson Island Pool, assumptions regarding the position of elevated metal levels in the sediment column and data on settling rates gathered from jar tests, an initial increase above ambient was determined from dredgehead losses (Table E-5, Appendix E). Ambient heavy metal values at Waterford between April 1975 and July 1976 were used. As Table E-5, (Appendix E) indicates, for the majority of heavy metals, neither dredging alternatives will create a significant increase. However, background concentrations in lead are fraquently three to ten times higher than ffYSDEC dredging certification standards and suspension of lead concentrated riverbed materials may cause significant increases in lead levels adjacent to Che dredgehead. Mercury levels in the river bed sediment were small, but background levels are high when compared to the NYSDEC standard. This metal requires monitoring during dredging due to its high toxicity. To a large degree, heavy metal losses at the dredgehead are based on dredge plume losses for hydraulic (2 percent) and clamshell (4 percent). Subsequently, heavy metal loss rates for the clamshell dredgehead are expected to be greater than hydraulic dredgehead. While most increases in heavy metals will be minor, lead and mercury increases will be significant. In addition to dredgehead losses, heavy metals will be added to the water eolumn from the return flow. The treatment process proposed for the return water is coagulation and sedimentation. It is difficult to estimate the heavy metal losses, but a rough approximation can be made baaed on jar testa of sediment samples collected from the Thompson Island Pool, Buoy 214 and Route 4 Bridge at Northcumberland. With the exception of cadmium, heavy metal levels in the unfiltered supernatant were within NYSDEC standards. The high cadmium concentra tion* may reflect a greater tendency for cadmium to desorb from sediments into the water. 4-45 HONS 009951 Using Che NYSDEC standard as a worse case situation, HP I (1978a) has estimated the return flow increases over Che ambient metal levels in the upper Hudson River. Table -6, (Appendix E) sutmarizes these increases and the dredge* head increases discussed earlier. Because hydraulic dredging return flow is larger than clamshell, relative increases in heavy metals are an order of magni tude higher. However, all of the anticipated heavy metal increases, with the possible exception of cadmium, are within the previously established KYSDEC certification standards. In combination with background heavy metal levels, however, Che levels may equal or exceed the standards, particularly for cad mium, lead and mercury (MPI, 1978a). Public Health KYSDEC has determined that the plume ceused by resuspension of river sediments will extend up to 1.6 km (1.0 mi) downstream of the dredging acti vity. The nearest water supply intake (for Stillwater) would be located 3.2 km (2.0 mi) downstream from the nearest dredging operations (at hot spot 36). The water supply inteke for Wsterford would be located 12.1 km (7.5 mi) downstream from the nearest dredging operations (at hoc spot 40). The draft SEQRA EIS (HPI, 1980d) reports: In the Thompson Island Pool, total PCB increases above ambient are estimated as: hydraulic dredge 0.3 ug/1; clamshell dredge, hydraulic pumpout with recycle 0.7 ug/1; clamshell dredge, hydraulic pumpout without recycle 0.8 ug/1. These estimates are based on the following assumptions: 3,000 cfs (85 cu m/s] river flow; 114 day project period for the hydraulic dredge, 81 days tor the clamshell; and PCB loss rates as discussed previously. Recent background levels for comparable flows at Schuylerville and Stillwater range from 0.5 to 1.0 ug/1 (Tofflemire and Quinn, 1979]. Clamshell dredging would be employed exclusively below the Thompson Island Dan. The ambient PCB increases shown for the Thompson Island Pool represent a "worst case", in that the estimated overall sediment PCB concentrations in the lower pools are approximately one-half that of the Thompson Island Pool (45 ug/g versus 96 ug/g including over cut). River flows average water column PCB increases for clamshell dredging below Thompson Island should be comparable to hydraulic dredging in the Thompson Island Pool. Therefore, under the worst case scenario, dissolved PCB levels would increase by 0.8 ug/l (ppb) immediately downstream from the dredging operation 4-46 MGNS 009952 at ehe Thompson Island Pool. The resulting ambient concentrations of PCBa at Stillwater could possibly increase during the dredging operations. The NYSDOH recommended guidelines for shore-term exposure to PCBs in drinking water is 1.0 ug/1 (ppb). Dredging of hot spots, particularly those in shallow water, will increase PCB concentrations in the air. Health risks will be greatest for workers involved in the dredging operation. Air concentrations of PCBs could exceed the recommended NIOSH 8-hour standard of 1 ug/cu en but will probably be well below the 500 ug/cu m OSHA standard. PCB air levels at homes in the vicinity of hot spots being dredged will elso be elevated, but such increases are not expected to exceed safe levels. Noise levels of the hydraulic dredge will be fairly constant, but not particularly high. Dredging operations will probably continue for 24 hours a day. People living near the river will be affected, especially at night. Fisheries and Aquatic Biota Impacts on biota from dredging operations will originate from two sourcea: destruction of benthic organisms and their habitat; and reductions in water quality. The removal of banthic organisms, which are food sources for fish, will vary significantly depending on the extent of dredging. While hydraulic or clamshell dredging will result in a similar disturbance of substrate, tha level of effort for the dredging will dictate the extent of overall disturbance and loss of habitat. Dredging of all 40 hot spots will disturb eight percent of the river bottom in the eight pools, while just dredging the hot spots in the Thompson Island Pool would disturb four percent of the river bottom. Organism recolonisation would be hindered by removal of parent stock and radical alter nation of the substrate, but migration from adjacent undisturbed areas should recolonise the dredged area in one to two seasons after dredging (MPI, 1980d). Under the full-scale project, hot spots in wetlands will be removed. Removal of the hot spot will destroy part or all of the wetland, possibly causing a substantial loas of wildlife habitat, loss of breeding and nursery areas for fish and other fauna, and alterations of food chain relationships. 4-4 7 HONS 009953 The principal water quality problem* which will affect aquatic organisms are increased levels of PCBa and heavy metals. Although the expected increases in PCB concentrations from the dredging activities are expected to be below the acute and chronic toxicity levels of most adult fish, the increases may be significant to sensitive species (MPI, 1978a). For example, spawning of the fathead minnow, a species known to inhabit the upper Hudson River, is affected by Aroclor 1242 at levels as low as 1.8 ug/1 (ppb) (USEPA, 1976a). The hydraulic dredge in combination with background levels could equal or exceed this level (MPI, 1978a). Increases in PCB levels in the water will increase PCB levels in exposed fish. The amount of increase would depend on the fraction of entrained, bio* logically active PCBs which is capable of moving across fish gill membranes. After dredging is complete and entrainment ceases, some of the bioconcentrated increment would be metabolized. However, the more chlorinated hydrocarbons are resistant to such breakdown. The impact of the PCBa on fish would be reduced with distance downstream (MPI, 1978a). The estimated increases in heavy metals, particularly cadmium and lead, may have adverse effects on certain sensitive fish species. For soft waters such as the upper Hudson River where dredging will occur, the EPA recommended criteria for cadmium are 0.4 ug/1 (ppb) for cladocerans and salmonids, and 4.0 ug/1 (ppb) for other aquatic forma (MPI, 1978a). Lead background levels as high as 300 ug/1 (ppb) have been measured at Waterford. Where lead levels are high in the bottom material, dredge-related entrainment could augment the background levels and aggravate existing adverse conditions (MPI, 1978a). Similarly, background mercury levels approach or exceed the EPA creterion of 0.05 ug/1 (ppb) for aquatic life. Increases against this background are not large but could exceed threshold values under existing conditions (MPI, 1978a). Suspended solids may cause sublethal effects on foraging ability and res* piration of fish immediately within the plume. Because of their mobility, how* ver, fish can avoid such turbid areas. Dredging conducted during the months of April and May would interfere with spawning, at least immediately downstream from the dredge (MPI, 1978a). 4-48 HONS 009954 Invertebrates could also be affected by increases in PCBs and heavy metals in the river during dredge operations. Invertebrate populations immediately downstream from the dredge sice could encounter increases in ambient PCBs de monstrated to be toxic in laboracory experiments. For example, a three-week exposure to 1.3 ug/l (ppb) Aroclor 1254 was observed to cause 50 percent mor tality in populations of the water flea Oaphnie (MPI, 1978a). It should be noted that benthic and planktonic organisms in the upper Hudson River already inhabit a highly contaminated environment, with background PCB levels which occasionally exceed 1 ug/l (ppb) (MPI, 1980a). The invertebrate situation with regard to heavy metals is similar to that of the fishery. Increases in cadmium could exceed che tolerance range of sen sitive species. Incresses in meTCury and lead may not be substantial, but may have significant effects in combination with high background levels. Increases in PCB and heavy metals in aquatic organisms would be transferred via the food chain to waterfowl and other organisms of higher trophic levels (MPI, 1978a). Agriculture and Terrestrial Biota Dredging of hot spots, particularly those in shallow water, will increase PCB contamination in the air, causing increased contamination of nearby ter restrial vegetation. Such contamination will be localized and at low levels. Operstion of the dredge equipment snd resulting noise will temporarily disrupt nearby wildlife habitats and possibly interfere with feeding, breeding and nesting. Hydursulic dredging will not have any significant short-term impacts on agriculture. Maintenance Dredging and Navigation Dredging activities will have adverse short-term effects on navigation in the river. Floating pipelines, and other dredging apparatus may hamper the peaaage of barges and other river traffic. If barges are used to transport 7.-A-20 4-49 HONS 009955 dredge spoils, they would also block river traffic, especially at the locks. Each operating dredge would generate four barge trips per day. and each barge trip would require 30 minutes of lock time (round-trip) in each lock upstream of dredging operations. Therefore, a single dredge would add two hours of lock time at each lock daily; two dredges, four hours; three dredges, six hours; and so forth. Depending on the amount of river traffic, these increases may result in occasional delays (MPI, 1978a). 3b. Clamshell Dredging Water Quality The clamshell dredging operation loses sediment during the raising and lowering of the bucket. The greater the water depth, the more sediment is lost from the bucket. Additionally, it is difficult, but not impossible, for the operator to overlap each bite of the bucket, resulting in a bottom with mounds and holes. However, this can be minimized by careful positioning of the clam shell bucket during operation. MPI (1978a) estimated dredgehead losses from a clamshell dredge to be 4 percent of the total material dredged. This is twice the material lose from the hydraulic dredge. If relative rates of removal are considered, then total losses for the clamshell dredging will be 1.5 times greater than the hydraulic dredge. Monitoring of side-by-side operation of a clamshell and hydraulic dredge in* dicetes that the clamshell tends to suspend more material than the hydraulic dredgehead (Tofflemire and others, 1979). However, problems developed with the testing equipment, as discussed under the previous section. Assuming that the amount of material to be dredged from the Thompson Island Pool is 840,000 cu m (1.1 million cu yd) and the average PCB concentration in this material is 50 ug/g (ppm), MPI (1978a) has estimated chat Che total amount of PCBs lost to the water column from the dredgehead is 235 kg (520 lbs). If an average flow of 85 cu m/s (3,000 cfs) is assumed, the estimated average PCB increase above ambient levels immediately downstream from the dredgehead is 0.4 ug/1 (ppm). Thtse increases would occur over a 20-hour work day. Because clamshell dredging will cause a larger dredge plume chan hydraulic dredging, it will also suspend more heavy metals at the dredgehead (Table 4-50 HONS 009956 E-5, Appendix E). However, return flow for clamshell dredging is less Chen hydraulic, producing less total loading of heavy metals to the river. Based on estimates which include loss from the dredgehead and return flow, clamshell dredging appears to minimize heavy metal losses to the weter column in comparison to the hydraulic dredge. However, the return flow concentrations were not empirically determined and may bias the calculations against the hydraulic dredge. It is therefore not possible to favor conclusively either dredging alternative with respect to heavy metals (MPI, 1978a). MF1 (1980d) estimates that the clamshell dredge would miss about 4 percent of the PCB contaminated sediment in the hot spots. However, Tofflemire end others (1979) estimates that 13 percent of the PCB will be missed during accurate dredging. This is a large difference and could have significant effects on PCB desorbtion and water column concentrations. Further investigations are necessary to evaluate this discrepancy. The volume of return flow for the clamshell dredging operation will be 20 times less than that ot the hydraulic dTedge because the water would be recycled back to the pumpout barge. The estimated increase in PCBa in the upper Hudson River caused by return water is 0.1 ug/1 (ppm) (MPI, 1978a). The total increase above ambient level due to the dredge plume and recycling of the pumpout water is 0.7 ug/1 (ppb) (MPI, 1980d). Clamshell dredging would be employed exclusively below the Thompson Island Pool. The ambient PCB increases shown for the Thompson Island Pool represent a "worst case", in that the estimated overall sediment PCB concentrations in the lower pools are approximately one-half that of the Thompson Island Pool (43 ug/g [ppm] versus 96 ug/g [ppm] including overcut). River flows would be higher due Co increased drainage basin area. Hence, average water column PCB increases for clamshell dredging below Thompson Island should be comparable to hydraulic dredging in the Thompson Island Pool. Public Health The impacts of clamshell dredging on the quality of downstream drinking water supplies will be similar to those discussed in Section 3a (Hydraulic Dredging) of this chapter. However, the impact of clamshell dredging may be 4-51 HONS 009957 lightly greater because it nay result in slightly higher concentrations of PCBs in Che river water. Air quality effects associated with clamshell dredging will be slightly more substantial than for Che hydraulic system. With the clamshell dredge, excavation may generate septic odors as the spoil is placed in che receiving barge. n addition, the agitation caused by the bucket entering and leaving the water surface, or water draining from the closed bucket may result in the entrainment of pathogens associated with contaminated sediments in airborn droplets. Vola tilization of PCBa will occur when the contaminated material is placed on che receiving barge and during the towing of the barge to the containment site. Noise levels from mechanical dredges are slightly higher than chose from hydraulic dredges. In addition there would be noise from the tugs that transport che barges and the pumpout barge. Operations are scheduled for 24 hours a day and may effect people living near the river. Fisheries and Aquatic Biota The clamshell dredge will have a slightly larger effect on aquatic biota than the hydraulic dredge. The increased concentrations of PCBs that may occur downstream from the dredgehead would increase biological PCB uptake within the areas of che dredge plume. Additionally, heavy metals placed into the water column by disturbance of rivar bed material could be incorporated into the food chain. Aa with hydraulic dredging, the full scope clamshell dredging program calls for removal of hot spots that are wetlands. Removal of such hot spots will result in the destruction of wetlands and subsequent loss of habitat apace. Additionally, any benthic communities associated with hot spots will be des troyed. Agriculture and Terrestrial Biota The impacts of clamshell dredging on nearby vagatation will ba similar to thoaa diacuasad for hydraulic dredging. PCB contamination of vagatation may ba slightly higher with clamshell dredging, however, because more PCBs may be 4-52 M0N3 009958 volatilized by clamshell dredging than hydraulic dredging. Clmhell dredging will alao create more noise, causing greater disruption of nearby wildlife habitats. Clamshell dredging will not have significant short-term impacts on agriculture. Navigation Clamshell dredging will have adverse short-term impacts on navigation in the river. During the removal of hot spots, dredging apparatus may block, river traffic. If barges are used to transport dredge spoils, they would also hamper river traffic, especially at the locks. Each operating dredge would generate four barge trips per day, and each barge trip would require 30 minutes of lock time (round trip) in each lock upstream of dredging operations. Therefore, a single dredge would add two hours of lock time at each lock daily; two dredges, four hours, and three dredges, six hours, and so forth. Depending on the amount of river traffic, these Increases may result in occasional delays (MPI, 1978a). 3c. Ocher Dredging Systems Various other dredging systems were evaluated in the alternative discus sions. Presently the mud cat dredge seems to be the only minor dredging option that seems feasible for this project. The mud cat dredge operates by using two augers chat loosen and feed the sediment to a suction pipe located beneath the dredge. The head is 2.5 m (8.0 ft) wide and can take as little as a 0.5 m (1.5 ft) thick cut. Water quality effects from operation of the mud cat would be similar to Che hydraulic dredge. Because the mud cats would be used for limited work in shallow areas, effects would be proportional to its use. 3B. Long-term Primary Impacts The long-term primary impacts associated with the removal of PCBs from the Hudson River under the full-scale project and reduced-scale project have been discussed in Sections 1.4 and 1.5 of this chapter. 4-53 HONS 009959 3C. Secondary Impacts The secondary impacts associated with the removal of PCBs from the Hudson River under the full-scale project and reduced-scale project have been discussed in Sections 1.4 and 1.5 of this chapter. 3D. Unavoidable Adverse Impacts and Steps to be Taken to Minimise Harm Unavoidable adverse impacts from the dredging mechanisms are: (a) suspen sion of PCB-contaminated material at the dredgehead of the various dredging units; (2) missed PCB-contaminated material; and (3) PCBs returned to the river in the return water flow. Measures to limit adverse environmental effects and maximize the efficiency of the PCB removal, as given by MPI (1980d), are: Dredging # Hot Spot Delineation--Additional PCB sediment samples will be taken for lower pools prior to any remedial dredging to better define the depth and areal extent of contamination. The existing sediment PCB data base is accurate enough for planning, but not implementation of a hot spot dredging program. The data are fairly complete for the upper pools, but become more intermittent with distance downstream. Additional data are desirable to define more precisely the hot spots to insure accurate removal of contaminated material. Scheduling--Dredging would cake place during the low-flow period between May 15 and September 15 (or until higher flows resume in the fall) to minimiza downstream PCB losses. e Operation Precautions, Hydraulic Dredge--PCB losses from the hydraulic dredge would be minimized by contrectual control of the cutter and swing speed. 4-54 MGNS 009960  Operation Precautions, Clamshell Dredge--PCB losses from the clamshell dredge would be reduced by limiting the hoisting speed through the water column, and by positioning the dredge and receiving barge so as to minimize the length of bucket swing above the water. Hydraulic Dredge Modifications--The feasibility of placing a shroud over the top of the cuter in order to increase suction efficiency and limit the escape of suspended material will be examined carefully. e Clamshell Dredge Modifications--Tight seals on the bucket lips will be required. The feasibility of placing a shroud over the top of the bucket or completely enclosing the bucket to reduce washout during hoisting will be assessed in the design phase. Floating Boom--When dredging results in a floating scum, a floating boom would be positioned downstream from the work sice. The employment of such e boom should not impede navigation and would be dependent on favoreble current conditions. The boom would be cleaned at least daily, and the trapped materiel placed in the disposal site. Silt Curtain--Where dredging results in an extensive surface plume s silt curtain mey be required. The curtain would extend from the water surface to e point midway in the weter column. Marsh Restoration--If it is determined that the benefits of dredging e particular contaminated marsh hot spot outweigh the adverse impacts of habitet loss, and one or more wetlands ere removed, marsh restoration may be a feasible mitigating measure. Garbish (1979) has outlined the steps required for marsh requirement following dredging, which are summarized below: -- Dredged areas filled with uncontaminated sediments to predetermined above-grade elevation. -- Following settling and consolidation, areas fiLled and/or graded to final elevation. HONS 009961 -- Upstream structures may be required to minimize scour; downstream silt screens may be needed to minimize sediment loss. -- After final grading, nursery grown stock or sprigs from nearby marshes transplanted, maintained for at least one season. Garbish (1979) notes that replacement plants must be set out at Che same elevations chat pre-existing or nearby plants of the sane species are estab lished. Avoidance of areas subject to high velocity and scour is necessary in achieving successful restoration. Garbiah reports successful regeneration of wetlands with Peltandra virginica (arrow arum), Pontedecia cordata (pickerel weed), Sagittaria latifolia (duck potato), Scirpus americanus (American three square), Typha sp. (cattails), and Leesia oryzoides (rice cut grass). All of these species are found in the existing upper Hudson River marshes. Shoreline Conditions--During the dredging design phase detailed field studies and analyses will be undertaken to minimize interference with overhanging trees and to avoid river bank instability. Dredged Material transport Hydraulic Dredge Pipeline--Where navigation may be impeded ie would be necessary to submerge the pipeline. a Pipeline Leaks--While small leaks are inevitable, operation would be stopped immediately if a major leak or a break occurs. a Hydraulic Pumpout of Barges--In order to reduce leakage, welded connec tions would be used in the pipeline construction, and a check valve would be installed at the pumpout station to prevent backflow. Loading of Barges--Sufficient freeboard must be maintained inside the barge to prevent overflow or spillage during transport. Alternatively, a 4-56 MONS 009962 splashboard could be installed around the top of the barge, permitting complete filling and thereby maximizing productivity. 3E. Contingency Plans Monitoring will be ongoing during the dredging operation in order to have continuous information on the water quality effects resulting from disturbances of the river bottom. If levels exceed standards, the dredging operation will be halted. If PCB and heavy metal concentrations in the water column near public water supply intakes exceed safe limits additional treatment or alternative water supplies will be required. 3F. Monitoring In the design phase, provision of an on-site laboratory for analysis of PCB samples taken ahead of the dredge will be evaluated. An abbreviated technique would suffice which should measure total PCBs as being either less or greater chan 30 ug/g (ppm). The extraction technique developed by GE, which has en approximate turn-around time of 1 hour, will be investigated. Materials which tend to occur with PCB, such as cesium 137 and lead, could also be monitored. The distribution of cesium 137, a nuclear testing fallout product, is closely correlated with PCB, and the analysis procedure for cesium may be simpler than chat for PCBs. Lead is slightly less closely correlated with PCBs. Sufficient samples should be taken to document any water quality impact of hot spot dradging, and to ensure compliance with certification standards estab lished by NYSDEC. A minimum program should include sampling for PCBa, lead, chromium, suspended solids and turbidity. Monitoring for airborne PCBs should be conducted at the dredge sites. 7:A-28 4-57 HONS 009963 Intensive monitoring would be conducted during early phases of excavation or dredging of materials with high concentrations of PCBs. If air PCB concentra tions are acceptable at these areas, monitoring would be reduced during excava tion or dredging of less contaminated areas. 4. Containment Sice Disposal of the contaminated dredge spoils by any means ocher thsn upland containment in a secure landfill is considered infeasible at this time. Spoil biodegradation and physical destruction are not cost-effective when dealing with the volumes of spoil that will be generated by this project. Other potentially feasible processes are not yet operational on a large scale. Therefore, the need for a secure containment facility is an important part of any dredging alternative for removal of PCB-contaminated sediments from the upper Hudson River. 4A. Short-Term Primary Impacts Primary impacts associated with the containment site are the disturbances caused by construction activities, water quality changes resulting from discharge to the Hudson River of the return flow, air quality changes resulting from volatilisation of PCBs from the dredge spoil, end effects to groundwater caused by infiltration of leachate. Public Health Tha protection of public health from volatilization of PCBs of the dredge spoils during placement of the spoils in the containment facility, discharge of PCB-contmoinated return water to the Hudson River, infiltration of leachate to ehe groundwater and disturbance from the construction processes is of paramount importance in the operation of the proposed project. With the inclusion of specific mitigating measures outlined in section 4d of this chapter potential environmental impacts will be minimized. 4-58 HONS 009964 In order Co comply with Che NYSDOH recommendation thee PCB concentration* in the air et residences not exceed 1.0 ug/cu m for any 24-hour period (Appendix I)( mitigating measures nay be necessary to reduce volatilization from the sice during placement of the dredge spoils (Appendix J). If the dissolved concentra tion of PCBs in the containment area exceeds 28 ug/1 (according to WAPORA), or 43 ug/1 (according to MPI) during the dredging operations, and adverse meteoro logical conditions occur as well, then it has been computed that the NYSDOH air quality recommendation could be violated ac the nearest residence (Appendix J). However, under normal meteorological conditions it is predicted that the NYSDOH guideline will not be exceeded with any regularity. However, it has been demonstrated that PCBs do volatilize from the water column of the Hudson River and from PCB-cOntaminated sediments in the remnant deposits and river bed. Tofflemire (1980) has estimated that 1,360 kg/yr (300 lb /yr) of PCB is presently being released from existing contaminated land fills and dumpaites in the upper Hudson Basin. Elevated ambient PCB levels have been observed at several contaminated dumpsices and concentrations exceeding the NIOSH 8-hour recommendation have been recorded at dumpsitea in the Fort Edward and Glens Falls areas. Additionally, the BTI (1978) sampled plants near the Fort Miller dumpeite in order to determine a relationship between foliar PCB levels and distance from a source of PCB volatilization. From their sampling program at the Fort Miller dumpaice and PCB contaminated dredge spoil disposal sites they determined the following: e At the Fort Miller dumpsite elevated foliar PCB levels were obtained at distances as far aa 700 m (2300) ft from the dump. Measurable increases in foliar PCB levels were apparent within 100 m (330 ft) of the Buoy 212 dredge spoil disposal site. Elevated foliar PCB levels were apparent within 200 m (640 ft) of the old Moreau dredge spoil disposal site and are expected to approach the limits of detection (i.e. undistinguishable from background levels) as far aa 300 m (980 ft) from the site. 4-59 MOWS 009965 Thesa examples illustrate the volatile nature of PCBs and the potential environ* mental effects from atmospheric losses while the dredge spoils are being placed in the containment site. Under the hydraulic dredging alternative, the average return water flow will be 3,780 cu m/dClO mgd). This water is mixed with the dredged material at the dredgehead and used to transport Che sediments by pipeline to the containment site. At the containment site, the sediment and water will flow through a series of settling lagoons to produce a nearly sediment-free water. At this point it will enter a water treatment plant to remove suspended particulates with PCBs. The plant will have a capacity of 49,200 cu m/d (13 mgd) and consist of coagu lation, flocculation and sedimentation units. For hydraulic dredging of the Thompson Island Pool, an estimated 70 kg (160 lb) of PCBs would be lost via the return flow per year. Such a loss would result in an increase above ambient of 0.1 ug/1 (ppb), assuming complete dilution of the effluent in 85 cu m/s (3,000 cfs). - In addition to heavy metal dredgehead losses, heavy metals will be added to the water column from the return flow. The treatment process proposed for the return water is coagulation and sedimentation. It is difficult to estimate the heavy metal losses that will occur, but rough approximation can be made based on jar tests of sediment samples collected from the Thompson Island Pool, Buoy 214 and Route 4 Bridge at Northumberland. With the exception of cadmium, heavy metal levels in the unfiltered supernatant were within NYSDEC standards. The high cadmium concentrations may reflect a greater tendency for cadmium to desorb from sediments into the water compared to other heavy metala. Using the NYSDEC standard as a worst case situtation, MPI (1978a) has estimated the return flow increases over tha ambient metal levels in the upper Hudson River. Table E-5 (Appendix E) summarizes these increases and the dredge head increases discussed earlier. Because hydraulic dredging return flow is larger Chan that for clamshell dredging, relative increases in heavy metals are an order of magnitude higher. However, all of the anticipated heavy metal increases, with the possible exception of cadmium, are within tha previously established NYSDEC certification standards. In combination with background heavy metal lavels, however, the standards may be equaled or exceeded, particularly for cadmium, lead and mercury (MPI, 1978a). 4-60 HONS 009966 The volume of recurn flow for Che clamshell dredging operation will be 20 Cimes leas Chan chat for Che hydraulic dredge, because Che water would be recycled back Co Che pumpout barge. A leachate will develop as a result of the drainage of che interstitial water in the dredge spoil. MPI (1980b) has estimated that 344,000 cu m (91 million gal) of interstitial water will be entrained in the dredge spoil. The substratum at the site will fora an effective barrier to the downward migration of this leachate. The substratum consists of a very poorly permeable clay with ~7 ~6 "8 a permeability that ranges from 2.3 x 10 to 5.88 x 10 cm/s (9.3 x 10 to 2.3 x 10 ^ in/s). At present Che thickness of Chis material varies from 1.3 m (4.5 ft) in che south to 17 a (57 ft) in the west. The site will be graded to approximately 43 m (144 ft) above sea level. On the average, approximately 9 a (30 ft) of clay will remain beneath the site once it is completed. EPA and NYSOEC regulations regarding the siting of secure landfills requires a minimum of 3 m (10 ft) of relatively impermeable material be above bedrock. This site will satisfy these requirements. Migration of leachate from the base of the 94 -q site is estimated to occur at the rate of 2.4 x 10 m/d (8.0 x 10 ft/d). It is expected to cake 600 years for the leachate to travel a distance or 60 m (200 ft) to the property line (MPI, 1980d). The nearest well is approximately 500 m (150 ft) west of the exterior dike of containment structure. Additionally, PCB and heavy metal movement would be further retarded by adsorption onto che clay particles, possibly reducing their movement 100 to 10,000 times below the water flow rate (MPI, I980d). Groundwater impacts from leachaCe generated at the containment site are expected Co be minimal. The clay material at the sice will not only serve as the base of Che con tainment facility, but will also provide soil to form the exterior and interior dikes.; It is estimated Chat for water within Che containment facility to seep to the outside face of the dike it would take in excess of 1,000 years (Richards, April 22, 1980). Noise levels in the area around the containment site will increase tempo rarily during construction of the facility and placement of che dredge spoil. Construction noise will originate from heavy earth moving equipment, increased traffic and other construction related activities. During placement the site will operate 20 hours a day, generating noise from pumping stations, earth moving equipment and increased traffic. M0NS 009967 4-61 Fisheries and Aquatic Biota Discharge of recurn flow Co Che Hudson River will effect water quality in the river. Return flow generated from the containment site during operation would contain some PCBs and would be treated prior to discharge to the river. The treatment process will consist of sedimentation, flocculation, and coa gulation and will only remove PCBs adsorbed to the solid material. Since the treatment process will remove the solid material, effluent PCBs will be primarily those dissolved in the water. Based on an average PCB concentration in the hot spot material of 120 ug/g (ppm) and a maximum concentration of 1,516 ug/g (ppm), the following effluent PCB concentrations are predicted (MPX, 1980d): a Average: 10 to 20 ug/1 (ppm) a Maximum: 100 ug/1 (ppm) a Minimum: 4 ug/1 (ppm) Based on these projections, it is estimated that 70 kg (160 lb) of PCBs will be lost to the river with hydraulic dredging of the Thompson Island Pool hot spots. With clamshell dredging and hydraulic cycle pumpout unloading, 9 kg (20 lb) of PCBs will be lost for each year's dredging. If the pumpout water were not recycled, an estimated 68 kg (150 lb) would be lost during the first yeer and 59 kg (130 lb) during the second year (MPI, 1980d). Impacts to the fisheries end aquatic biota will be less with clamshell dredging end hydraulic pumpout unloading chan with hydraulic dredging. Site dewatering will produce an additional 344,000 cu m/d (91 mgd), which will drain through a collection system to the river. At sn estimated PCB concentra tion of 10 ug/1 (ppb), this drainage water would contain some 3.4 kg (7.6 lb) of PCBs (MPI, 1980d). Effects to aquatic biota and fisheries would be minimal. Agriculture and Terrestrial Biota The area around the containment site is used for growing of certain crops and gracing of cows. Volatilization of PCBs from the dredge spoils will increase levels in crops and grazing forage for fields near the site. Based on the PCB 4-62 MOMS 009968 volatilization and dispersion models (Appendix J), the PC8 levels in the various crops (including corn with cob and ear only; corn with stem, ear, cob, cassle, and leaf; alfalfa; red clover; and timothy) should be monitored at approximately 100-m (330-ft) intervals to a distance from the containment site at which all foliar PCB levels are below the FDA maximum allowable level of 0.2 ug/g (ppm) for forage. Based on work by Buckley (1980) it is expected that corn, with cob and ear only, will be less contaminated with PCBs than corn with stem, ear, cob, tassles, and leaves; corn with stem, ear, cob, tassles, and leaves will be less contaminated chan alfalfa; alfalfa will be less contaminated chan red clover; and red clover will be less contaminated than timothy. Therefore, vegetation should be monitored before cattle are permitted to graze within 2,000 m (6,600 ft) of the containment site. Wildlife habitat at the site of Che containment facility will be destroyed. In addition, noise from construction activity will disrupt nearby wildlife habitats and interfere with normal feeding, breeding, and nesting activities. Maintenance Dredging and Navigation Disposal of contaminated dredge materials will not have significant impacts on maintenance dredging and navigation. 4B. Long-Term Primary Impacts Public Health Leachate will be collected by an underdraining system consisting of (1) gravel filled collection trenches, wrapped with filter fabric; (2) perforated drainage piping in the collection trenches; (3) collection and sampling well along the containment area perimeter; (4) piping system connecting the drainage system to a discharge point at the Hudson River and 3) flow meterizing and monitoring system. 4-63 MOWS 009969 Th leachate collection system consists of gravel filled collection trenches that have a potential for clogging if a large portion of fine grained sediment is contained in the dredge spoil. If this happens, the interstitial water will be unable to drain and the water will remain within the containment facility. Although the capping material is very poorly permeable, MPI (1980c) estimates that long term infiltration through the cover will be 3.1 cm (1.25 in) per year. If this input is unable to drain out, it may develop a hydraulic head within the closed contsinment facility that could lift the clay cover at a low point. MPI (L980d) estimates that total annual leachate will be approximately 8,320 cu m/yr (2.2 million gal/yr). At 10 ug/1 (ppb), this leachate would discharge 0.08 kg (0.2 Lbs) per year to the river. At present, leachate will be drained to the river untreated, but options for leachate treatment are available. Howtver, estimates of leachate quantity and concentration indicate thae effects to the river will be minimal from the untreated leachate (MPI, I980d). Stormwater management controls are described in MPI (1980d). All sit* drainage will be conveyed to the Hudson River during construction end after closure. PCBs and sediment concentrations in the drainage may be elevated during emplacement, but should decrease significantly after closure. Effects to water quality in the Hudson are expected to be minimel. Additionally, the clay cover will effectively prevent long-term migration of PCBs into the groundwater. The shale bedrock underlying the containment site will bear the additional weight of the filled end closed containment structure without rupturing or collapsing. Presently, there is Ho 22 n (30 to 75 ft) of saturated clay overlying the shale. The addition of the dredge spoil to the clay overburden will not effect the shale's ability to bear the weight of both the clay and filled containment facility. Once the contaiment area is stabilized and permanently capped, the vola tilization of PCBs will decrease markedly. An important factor in any long-term 4-64 HONS 009970 impact assessment would be which of the two options presently being considered for the cap is chosen. One option included in the plan is the installation of a capped continuous venting and control system. The ocher option is to install capped venting system immediately, but to wait and see if monitoring daea show that significant amounts of PCBs are being volatized before installing a control system. Either of these options appear acceptable as long as the funding for any future control system is sec aside and available if necessary. In addition, it appears that Che second option may be most cost-effective as it is quite possible that emissions from the covered containment site will be minimal. 4C. Secondary Impacts The presence of a hazardous waste containment facility may lower markee values for adjacent property. In addition, state acquisition will remove real property from the tax rolls and reduce the property tax revenues for the local school district and local governments. Use of the property ta s containment facility will reduce the amount of land available for development. This will not result in s significant shortage of land for development because of the anticipated low rate of growth, current leek of development pressure, and the already large supply of vacant land in the region. 4D. Mitigating Measures Unavoidable adverse impacts will originate largely from volatilization of PCBs at the containment site during emplacement of dredge spoils. Mitigating measures may be necessary to reduce the volatilization from sections of the containment site nearest the local homes (section numbers 13, 14, 15, 16 and 17 indicated on Figure 4-1). After capping volatilization will decrease signi ficantly. Mitigating measures that may be taken to minimize potential environmental impacts from the containment site are: 4-65 HONS 009971  Protective clothing would be available for operators and other personnel at the dredging and containment sites. This would include respirators and protective gloves. PCB air concentrations at the containment site will exceed the NIOSH 8-hour reconnendation Cl ug/cu to), but they will be well below the OSHA 8--hour standard (500 ug/cu n>) . Therefore, use of Che protective clothing would not be required. e A six-foot security fence should surround the active disposal area from the initiation of sice use (MPI, 19804). e The containment site could be divided into smaller cells thereby reducing total emissions at any given time during the disposel operations. High surface tension monomolecular films and adsorbents should be studied to determine if their use would substantially reduce volatilisation. Less contaminated dredge spoils should be placed in those containment cells nearest the occupied residences. The clay cover should be put in place as soon as a given contairaaent site cell is filled and dewatered enough to support the weight of con struction equipment (MPI, 1980d). Adequate topsoil, fertilizer, seed, and water will be applied to estab lish a thick vigorous cover. Over time the vegetation would be allowed to revert to a mixture of pasture plants. The cover should be mowed a minimum of once per year to prevent growth of deep-rooted plants (MPI, 1980d). a The cover surface would be inspected regularly for slope failure, cracks, holes, and depressions. These would be filled and reseeded to maintain an even surface. Lime would be applied periodically (MPI, 19804). a Burrowing animals, such as woodchucks, which may inhabit the site, would be controlled by trapping (MPI, 1980d). 4E. Contingency Plans Despite the precautionary measures taken in the design, construction, and operation of a containment facility, there still is some potential for accidental failure of the containment area. Although this possibility is considered remote, such an event would be likely to contaminate local groundwater supplies. This would require New York State to obtain alternate water supply sources or treat the contaminated supplies. 4F. Monitoring Monitoring at che containment site will concentrate on PCB levels in ground water, leachate, stormwater runoff and air quality. 4-66 MOMS 009972 The groundwater monitoring network for Che containment sice consists of six monitoring points adjacent to the active disposal portions of the site. Each monitoring point will have three observation/monitoring wells: A 3-o ClO-ft) section; 3.S cm (1.5 in) in diameter, schedule 80 PVC pipe with 1 m (3 ft) of 10 slot screen; A 6-o C20--ft) section; 3.8 cm (1.5 in) in diameter,schedule 80 PVC pipe with 1 m (3 ft) of 10 slot screen; e A 9-m (30-ft) section; 10 cm (4 in) in diameter, schedule 40 PVC pipe with 1.5 m (5 ft) of 10 slot screen. These cased wells with friction type couplings will be installed by the chopping and wash method. Each veil will be backfilled with clean, well sorted sand around and 0.6 m (2 ft) above the cop of the screen. The remainder of the hole will be filled with a bentonite grout and surrounded by a 1.5-m (5-ft) protective sleeve with a locking cap. When bedrock is encountered within the 9-m (30-ft) depth, the 10-cm (4-in) in diameter well will be set 1.5 to (5 ft) into the bedrock (MPI, 1980a). Leachate will be sampled periodically through the collection and sampling wells connected to the drainage pipe. Storm water runoff will be collected and sampled periodically (MPI, 1980a). A system of gas sampling and venting wells will be installed in the con tainment area cover. These outlets will be valved to prevent the escape of PCBs through volatilisation. Gas pressure and compositon will be monitored regularly and the valves will only be opened if necessary to prevent breeching of the cap. If significant quantities of gas are generated, and if the gas does not contain appreciable levels of PC3s, then the valves will be left open. If gas does contain high levels of PCBs, appropriate provisions for collection and disposal will be implemented (MPI, 1980a). Volatilisation during emplacement of the contaminated dredge spoil can cause significant release of PCBs. The surrounding air quality and vegetation will be continuously monitored for elevated PCB levels. 4-67 HONS 009973 FEDERAL, STATE, LOCAL AND OTHER SOURCES FROM WHICH COMMENTS HAVE BEEN REQUESTED Federal Agencies: Army Corps of Engineers Council on Environmental Quality Coaae Guard Department of Agriculture Department of Conmeree Department of Health and Human Services Department of Housing and Urban Development Environmental Protection Agency Executive Office of the President Flah and Wildlife Service Geological Survey Heritage Conservation and Recreation Service Office of Management and Budget United States Senate: Honorable Alfonse D'Amato Honorable Daniel P. Moynlhan United States House of Representatives: Honorable Gerald Solomon Office of the Governor: Honorable Hugh Carey New York State Senate: Honorable Joseph Bruno Honorable Hugh Farley Honorable Ronald Stafford Nev York State Assembly: Honorable Joan Hague Honorable Robert D'Andrea Honorable Andrew Ryan, Jr. State Agendas: Department of Agriculture end Markets Department of Commerce Department of Environmental Conservation Department of Health Department of Transportation Great Lakes Basin Commission Power Authority 5-1 HONS 009974 County Agencies: Dutchess County Environmental Management Council Rockland County Department of Health Washington County Board of Supervisors Washington County Planning Department Local Agencies: Town of Greenwich Planning Board Groups and Organizations: Citizens Advisory Committee Conservation Board, Town of Pound Ridge Council of Agricultural Organizations, Inc. Environmental Affairs Groups Federation of Dutchess County Fish and Game Clubs, Inc. Friends of Long Island National Resources Defense Council New Rochelle Environmental Impact Advisory Commission Scenic Hudson Inc. Settlement Advisory Committee Sierra Club, Atlantic Chapter Yonkers Environmental Impact Advisory Commission 5-2 MONS 009975 BTI bu C cfs CO cu ft cu m cu yd CWA d DEIS EIS EPA F FDA ft 1*1 S GE gpd *pn ha in hg km 1 lb LMS lpd lp n mgd * mi ABBREVIATIONS USED acre Boyce Thompson Institute bushel Celcius cubic feet per second centimeters cubic foot cubic meter cubic yard Clean Water Act d4y Draft Environmental Impact Statement Environmental Impact Statement United States Environmental Protection Agency Farenheit United States Food and Drug Administration foot galIon gram General Electric Corporation gallons per day gallons per minute hectare inch kilogram kilometer liter pound Lawler, Matusky and Skelly Engineers liters/per day liters per minute meter million gallona/day milligram mile 6-1 HONS 009976 tnra MPI MRJD NEPA NIOSH NMPC NOAA NO I NPS NYSDEC NIOSH NOAA NOI NPS NYSDEC NYSDOH NYSDOT OSHA PCS PCFD PPb ppo s sq km q m SEQRA SHPO USACOE USDASCS USDC USFWS uses usscs uv ug y* millimeter Malcora Pirnie, Inc. Juser, Rutledge, Johnston end Desimore, Consulting Engineers National Environmental Policy Act National Institute for Occupational Safety and Health Niagara Mohawk Power Company National Oceanic and Atmospheric Administration Notice of Intent non-point source New Yorl Policy Act National Institute for Occupational Safety and Health National Oceanic and Atmospheric Administration Notice of Intent non-point source New York State Department of Environmental Conservation New York State Department of Health New York State Department of Transportation Occupational Safety and Health Administration Polychlorinated biphenyl Polychlorinated dibenzofuran parts per billion parts per million second square kilometer square mile State Environmental Quality Review Act State Hiatoric Preservation Office United States Army Corps of Engineers United States Department of Agriculture Soil Conservation Service United States Department of Commerce United States Fish and Wildlife Service United States Geological Survey United States Soil Conservation Service ultraviolet microgram year HONS 009977 6-2 Metric celciua (C) centimeter (cm) cubic meter (cu m) gram (g) hectare (ha) kilogram (kg) kilometer (km) liter (1) meter (m) metric con (t) microgram per gram (ug/g) micrograa per liter (ug/1) milligram per liter (mg/1) millimeter (mm) English Farenheit (F) inch (in) cubic yard (cu yd) cubic foot (cu ft) gallon (gal) pound (lb) acre (a) pound (lb) mile (mi) gallon (gal) yard (yd) foot (ft) ton (tn) part per million (ppm) part per billion (ppb)* part per million (ppm)* inch l in) Note: 1. an approximate equivalent 7HONS 009978 REFERENCES Aliberci, Patrick (oral communication). March 2, 1981. Conversation between Patrick Aliberti, Insurance Advisor, New York State Office of General Services, Albany, New York, and Charles Marcus, Planner, WAPORA, Inc., New York, New York. Algernieeen, S.T., and D.M. Perkins. 1976. A probabilistic estimate of maximum acceleration in rock in the contiguous United States. U.S. Geological Survey, Open File Report No. 76-416, Washington, DC. Allen, J.R. and others. 1974. Tissue modifications in monkeys as related to ab sorption, distribution, and excretion of polychlorinated biphenyls. Archives of Environmental Contamination and Toxicology. 2:86. Armstrong, Roger W., and Ronald J. Sloan. 1980. Trends in levels of several known chemical contaminants in fish from New York State waters. 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Polychlorinated biphenyls in sediments of the tidal Hudson River, New York. Environmental Science and Technology. 15(2): 210-215. Boycs Thompson Institute for Plant Research, Inc. 1977. An atlas of the bio logic resources of the Hudson Estuary. Boyce Thompson Institute for Plant Research, Inc. Yonkers, New York. Buckley, E.H. 1980. PCBs invegetation. Boyce Thompson Institute for Plant Research, Inc. Prepared for New York State Department of Environsiental Conservation, Albany, New York. 33 pp. Buckley, E.H. (written consunication). February 6, 1981. Letter from E.H. Buckley, Boyce Thompson Institute for Plant Research, Inc., Ithaca, New York, to James Tofflemire, Senior Scientist, New York State Department of Environmental Conservation, Bureau of Water Research, Albany, New York. 8-1 HONS 009979 Buckley, E.H. (oral communication). March 24, 1981. Conversation between E.H. Buckley, Botanist, Boyce Thompson Institute for Plant Research, Ithaca, New York and James Mack, Geologist, WAFORA, Inc., New York, New York. Buckley, E.H. (oral communication). April 9, 1981. Conversation between E.H. Buckley, Botanist, Boyce Thompson Institute for Plant Research, Ithaca, New York and Howard Schwartz, Project Manager, WAPORA, Inc., New York, New York. Camp, Dresser and McKee, Environmental Consultants. 1960. Generic environmental impact statement for a hazardous waste treatment facility in New York State. Prepared for New York State Department of Environmental Conservation, Albany, New York. (2 volumes). Clarkson and Clough. 1970. In: PCB in the upper Hudson River: Mapping and sediment relationships. Technical report 56, April 1979. New York State Department of Environmental Conservation, Albany, New York. Collison, James (oral communication). February 27, 1981. Conversation between James Collison, Director, New York State Department of . Transportation, Real Estate Division, Albany, New York, and Charles Marcus, Planner, WAPORA, Inc., New York, New York. Cotter, J. E., and R. J. Johnson. I960. Facilities evaluation of high effi ciency boiler destruction of PCB waste. Prepared by TRW, Inc., for USEPA, Industrial Environmental Research Laboratory, Research Triangle Park, North Carolina. Cranston, W.M. (written communication). August 25, 1977. Letter from W.M. Cranston, City Manager, City of Poughkeepsie, to the Common Council, City of Poughkeepsie, Municipal Building, Poughkeepsie, New York. Curll, Daniel. (oral commuinication). March 24, 1981. Statement by Daniel Curll, Save Our Ports, New York, New York, at Citizens Advisory Committee meeting for Hudson River PCB Reclamation Project, Poughkeepsie, New York. Dovel, W.L. 1979. The endangered shortnose sturgeon of the Hudson River: Its life history and vulnerability to the activities of man. Progress Report No. 6. Submitted to Federal Energy Regulatory Commission. Dovel, W.L. 1980. The endangered sturgeon of the Hudson River: Its life history and vulnerability to the activities of man. Progress Report No.7 Submitted to Federal Energy Regulatory Commission. Dovel, W.L. (written communication). February 23, 1981. Letter from William L. Dovel, Biologist, Oceanic Society, Stanford, Connecticut, to Howard Schwartz, Biologist, WAPORA, Inc., New York, New York. Farrell, J.B. and H. Wall. 1981. Air pollutional discharges from ten sewage sludge incinerators. Unpublished draft dated January 20, 1981. US Environ mental Protection Agency, Cincinnati, Ohio. Gahagan and Bryant, Assoc. April, 1980. Dredging of PCB contaminated hot spots, upper Hudson River, New York. Dredging system report prepared for Malcolm Pirnie, Inc., White Plains, New York. 9:A-G3 8-2 HONS 009980 Carbish, E.W. (written communication) 1979. Letter from E.W. Carbish, Environ mental Concern, to New York State Department of Environmental Conservation. 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Prepared for New York State Department of Environmental Conaervation Albany, New York. Variously paged. Lawler, Matusky and Skelly Engineers, 1979. Upper Hudson River PCB transport modeling study. Prepared for New York State Department of Environmental Conservation, Albany, New York. Variously paged. Mahanty, H.K. and B.A. Fineran, 1976. Effects of polychlorinated biphenyl (Aroclor 1242) on the uitrastructure of frond cells in the aquatic plant Spiradala illiguriza (Kurz) Hegelm. New Zealand Journal of Botany 14 (1): 13-18. Malcolm Pirnie, Inc. 1978a. Feasibility report on dredging of PCB * contaminated river bed materials, upper Hudson River, New York. Three volumes. Prepared for New York State Department of Environmental Conservation, Albany, New York. Malcolm Pirnie, Inc.1978b. Phase 1 engineering report for dredging of PCB contaminated hot spots in the upper Hudson River, New York. Prepared for New York State Department of Environmental Conservation, Albany, New York. Malcolm Pirnie, 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 Pirnie, Inc. 1980b. PCB hoc spot dredging program containment site* design report. Prepared for New York State Department of Environmental Conservation, Albany, New York. Malcolm Pirnie, Inc. 1980c. PCB hot spot dredging program, upper Hudson River, dredging system report: Program Report No 2. Malcolm Pirnie, Inc. 1980d. PCB hot spot dredging program, upper Hudson River, New York. Draft environmental impact statement. Prepared for New York State Department of Environmental Conservation, Albany, New York. Melcola Pirnie, Inc. February, 1981. Draft PCB hot spot dredging program, upper Hudson River, New York rescoping report. Submitted to New York State Department of Environmental Conservation, Albany, New York. 8-4 MONS 009982 Marshall, Earnest W. (written communication). February 26, 1981. Ice transport of PCBa in the upper Hudson River. Written statement in transcript of the public meeting on the PCB hoc spot dredging program, at Poughkeepsie, New York. Matthews H. , and others 1979. Metabolism and biochemical toxicity of PCBs and PBBa. Environmental Health Perspective 24:147-144. In: National Research Council Polychlorinated Biphenyls, National Academy of Sciences, 1979. Murchelano R.A. 1980. Environmental quality and the diseases of fish and shellfish. Maritimes 24: 7-10. National Environmental Policy Act. 1975. 42 USC 4341; Amended by PL 94-52 July 3, 1975, and PL 94-83 Auguat 9, 1975. National Institute of Occupational Safety and Health. 1976. Registry of toxic effects of chemical substances. Newton, T.V. (oral communication). February 27, 1981. Oral input to transcripts of the public meeting on the PCB Hot Spot Dredging Program, at Hudson Falla, New York. Newton, T.V. (written communication). March 28, 1981. Soil information for proposed dump site (and dairy cattle information). New York State Department of Environmental Conservation. 1977a. Hudson River PCB study description and detailed work plan. New York State Department of Environmental Conservation. 1977b. PCB air sampling program. Division of Air Resources. Unpublished data. New York State Department of Environmental Conservation. 1979. New York State air quality report, continuous and manual air monitoring system. DAR-80-1. Albany, New York. New York State Department of Environmental Conservation. 1980. Hudson River PCB analyses - 1979, 1980 samples. Albany, New York. New York State Department of Environmental Conservation and United States Fish and Wildlife Service. 1978. Hudson River fish and wildlife report. Hudson River level B study. 27 pp. * appendices. Nichols Engineering and Research Corporation. 1978. Decontamination of PCB" laden Hudson River bottom sediment for General Electric in the 36-inch Nichols/Herreshoff Furnace. New Jersey. O'Connors, Harold B. Jr., Charles F. Wurster, C. Donald Powers, Douglas Biggs, Ralph G. Rowland. 1978. Polychlorinated biphenyls may alter aerine trophic pathways by reducing phytoplankton sire and production. Science 201:737-739. 8-5 MQNS 009963 Ravinski, Thom**, Richard Malecki, and Louise Mudrak. 1979. A guide Co planes commonly found in Che freshwater wetlands of New York State. Department of Natural Resources, Community Environment Program, Cornell University, Ithaca, New York. 29 pp. Richards, Elmer A. (written communication). April 22, 1980. Letter from Elmer A. Richards, Partner, Mueser-Rutlege-Johnston-Desimore, Consulting En gineers, to Steve Maslansky, Malcolm Pirnie, Inc., White Plains, New York. Sax, Irving N. 1979. Dangerous properties of industrial materials. 5th ed. Van Nostrand Reinhold Company, New York, New York. Sheppard, J. Douglas. 1976. Valuation of Hudson River fishery resources: past, present and future. Internal report, New York State Department of Environmental Conservation, Bureau of Fisheries, New York State Department of Environmental Conservation, Albany, New York. 51 pp. Shen, T.T., and T.J. Tofflemire. 1979. Air pollution aspect of land disposal of toxic waste. New York State Department of Environmental Conservation, Albany, New York. Sloan, Ronald J. (oral communication). March 10, 1981. Conversation between Ronald J. Sloan, Senior Scientist, New York State Department of Environmen tal Conservation, Albany, New York and Gregory T. Greene, Biologist, WAPORA, Inc., New York, New York. Slocum, John (oral communication). February 9, 1981. Oral input to transcripts of the scoping meeting for the EIS on the Hudson River reclamation/demon stration project, at Hudson Falls, New York. Smith, C. Lsvett, 1977. The Hudson River fish fauna, In: McKeon, Warren H. and Gerald J. Lauer (eds.) Hudson River ecology. Proceedings of a sympo sium, Hudson River Environmental Society Paper no. 32. 12 pp. Stork, Edward (oral communication). February 9, 1981. Oral input to transcripts of the scoping meeting for the EIS on the Hudson River reclamation/demon stration project, at Hudson Falls, New York. Sunohio. October 23, 1980. EPA witnesses at Sunohio PCBX demonstration. News Release. Thomann, Robert U., and St. John, John P. 1976. The fate of PCBs in the Hudson River ecosystem. Annals. New York Academy of Sciences. Thomas, Richard (oral communication). April 17, 1981. Conversation between Richard Thomaa, Project Manager, Malcolm Pirnie Inc., White Plains, and Howard Schwartz, Project Manager, WAPORA, Inc., New York, New York. Tofflemire, T.J. April, 1976. Preliminary report on sediment characteristics and water column interactions relative to dredging the upper Hudson River for PCB removal. Prepared for New York State Department of Environmental Conservation, Albany, New York. Tofflemire, T. J. (written cooounication), 1980. Memorandum from T.J Tofflemire, Senior Scientist, New York State Department of Environmental Conservation Albany, New York, to concerned parties on the Hudson River water data set. 8-6 HONS 009984 Tofflemire, T. d., 1980. PCE in sediments end water and their transport. Draft report. Prepared for New York State Department of Environmental Con servation, Albany, New York. Tofflemire, T.J. (written communication). March 11, 1981. Memorandum from Tofflemire, New York State Department of Environmental Conservation, Albany, New York, to Italo Carcich, Director, Bureau of Water Research, New York State Department of Environmental Conservation, Albany, New York. Tofflemire, T. J, and S. 0. Quinn. 1979. PCB in the upper Hudson River: mapping and sediment relationships. Technical Paper No. 56. Prepared for New York State Department of Environmental Conservation, Albany, New York. Tofflemire, T.J., L.J. Hetling, and S.O. Quinn. 1979. PCB in the upper Hudson River: sediment distribution, water interaction, and dredging. Prepared for New York State Department of Environmental Conservation, Albany, New York. Turner, D.B. 1970. Workbook of atmospheric dispersion estimates. U.S. Environ mental Protection Agency, Air Programs. Research Triangle Park, North Carolina. United States Department of Agriculture Soil Conservation Service. Soil survey of Washington County, New York. Washington, D.C. 1975. United States Department of Commerce. 1955. Rainfall intensity - duration frequency curves. Technical paper no. 25. Weather Bureau. United States Department of Commerce. 1959. Evaporation maps for the United States. Technicel paper no. 37. Weather Bureau. United States Department of Commerce. Water Information Center. 1974. Climates of the United States. United States Department of Commerce. 1976. Summary, New York State annual climatological data. Volume 88, Number 13. National Oceanic and Atmos pheric Administration. United States Environmental Protection Agency. 1976a. Quality criteria for water. EPA-4409-76-023. United States Environmental Protection Agency, Washington, D.C. United States Environmental Protection Agency. 1976b. Review of PCB levels in the environment. EPA-560/7-76-00l. PS-253-735. United States Environmental Protection Agency, 1976c. National Interim Primary Drinking Water Regulations. U.S. Environmental Protection Agency. Office of Water Supply, Weahington, D.C. EPA-570/9-76-003. United States Environmental Protection Agency, 1979. National Secondary Drinking Water Regulations. U.S. Environmental Protection Agency Office of Drinking Water, Washington, D.C. EPA-57O/9-76-OO0. United States Food and Drug Administration. 1979. An assessment of risk associ ated with the human consumption of some species of fish contaminated with polychlorinated biphenyls (PCB's). HW-129. PCB risk assessment work force, Washington D.C. 8-7 MOMS 009985 United States Geological Survey. 1975. Water resources data for New York. Water Resources Division, Albany, New York. United States Ceotogical Survey. 1980. Water resources data for New York. Water Resources Division, Albany, New York. Valentine, Ralph, S. 1981. LARC-light activated reduction of chemicals. Pollution Engineering, February. Vanoni, V.A. 1977. Sediment engineering. Prepared for Sediment Commission of the Hydraulic Division of the American Society of Civil Engineers, New York, New York. Weber, J. B., and E. Mrozek, Jr. 1979. Polychlorinated biphenyls: phytotoxicity, absorption and translocation by plants, and inactivation by activated carbon. Bulletin of Environmental Contamination and Toxicology 23:412*417. World Health Organization. 1974. LARC monographs on the evaluation of carcinogenic risks of chemicals to man. Volume 7. World Health Organization , 1976. Environmental health criteria 2: Polychlorinated biphenyls and zerphenyls. Geneva. 8-8 MQNS 009986 LIST OF PREFAREBS This EIS was prepared by WAPORA, Inc. under the technical direction of the following EPA Region II Environmental Impact Branch personnel: Robin Rohn Thomas Maher Richard Walks Charles Manning Steven Arella Jeffrey Zeliksen Project Officer Environmental Engineer Chief, New York/Virgin Island Section Chief, Statewide Program Section Chief, Environmental Impact Branch Deputy Director, Water Division The WAPORA staff members who prepared this document and their areas of respon sibility are lisced below: Principal Authors Howard Schwartz Gregory Creene Jamas Mack Kathleen Murray Joel Soden Project Manager/Water Resources Biology Geology Water Resources/Public Health Air Quality Alfred Angiola Paul Eisen Chris Salmi David Bush Louis Kajas Michael Keller James Marlowe Roger Moose Winston Lung Mary Lou Mod Catherine Sklntik San Klsng Contributing Authors Project Managemenc/Air Quality Air Quality Air Quality Air Quality Engineering/Water Quality Public Health Geology Geology Water Quality Editing Editing Air Quality 9-1 HONS 009987 APPENDIX A Human Exposure and Risk Assessment for Residents in the Vicinity of Operations Associated with the Dredging of the Upper Hudson River The material in Appendix A was compiled by WAPORA, Inc. principally from the following references: United States Environmental Protection Agency. 1976b. Review of PCB levels in the environment, EPA-560/7-76-001, PS-253-735. World Health Organisation. 1976. Environmental health criteria 2: Polychlorinated biphenyls and zerphenyls, Geneva, Switzerland. HONS 009988 Appendix A HUMAN EXPOSURE AND RISK ASSESSMENT FOR RESIDENTS IN THE VICINITY OF OPERATIONS ASSOCIATED WITH THE DREDGING OF THE UPPER HUDSON RIVER 1. HEALTH EFFECTS OF PCB EXPOSURE A 1976 study by the World Health Organization (WHO) indicates that nan appears to be the species most sensitive to PCBs. The monkey is the only expertmental species in which effects qualitatively and quantitatively approaching those in man have been observed; this has been attributed to metabolic dif ferences leading to a slower elimination than that observed in other species tested. Conclusions concerning the specific effects of PCBs on different species sre confused by uncertainty arising from the presence of toxic impurities. Rice oil that caused an outbreak of severe disease in Japan was contaminated with PCBs containing relatively high amounts of tetrachlorodibenzofuran, but the sample used in the monkey experiments had low concentrations of these impurities, so it is not clear whether PCBa alone were responsible for the incident in Japan. Further uncertainty arises from reports from Finland of high PCB con centration in blood and body fat of occupationally exposed workers with no indication of adverse effects, while at similar tissue concentrations Japanese workers showed skin lesions (WHO, 1976). Commercial PCBs are not sold on a composition specification, but on their physical properties. Impurities known to be present in commercial PCBs are chlorinated dibenaofurana and chlorinated naphthalenes. Chlorinated dibensofurans have been found at 0.8-3.0 mg/kg (ppm) in samples of the Aroclor 1246-1260 series, but none in Aroclor 1016, and at levels of 8.4 mg/kg (ppm) in Clophen A60 and 13.6 mg/kg (ppm) in Phanoclor DP-6. Chlorinated dibenzofurans have also been found at levels of 1 mg/kg (ppm) and 18 mg/kg (ppm) in different batches of Kanechlor 400 (WHO, 1976). A-l HONS 009989 A species-specific toxic manifestation that can probably be attributed to toxic impurities is the abdominal edema and hydropericardium seen in birds affected by some commercial PCB mixtures (WHO, 1976) Mink is another species with a high sensitivity to PCBs. Deaths have been produced with diets containing PCB levels of 30 mg/kg (ppm); no information is available on any species-specific metabolic pathway in the mink that would account for this susceptibility (WHO, 1976). The following is a summary of data concerning the relationship between mammalian toxicity and dose. Approximate calculations of the daily dose in mg/kg body weight derived from the dietary concentration are given in paren theses. When no food consumption figures were available from the experimental studies, the following factors were used to transform mg/kg (ppm) in the diet to mg/kg body weight: mouse (7), rat (20), guinea-pig (25), mink (10), rabbit (33), monkey (25) (WHO, 1976). la. Body Weight Body weight waa reduced in rats from 8 months of dietary intake of Aroclor 1254 and 100 mg/kg (corresppnding to 5 mg/kg body weight); no effects were observed at 20 mg/kg in the diet (corresponding to 1 mg/kg body weight) (WHO, 1976). Dose-dependent retardation of weight gain was observed in mink sfter 4 months of dietary intake of Aroclor 1254 at 5 and 10 mg/kg (corresponding to 0.5 and 1.1 mg/kg body weight respectively) (WHO, 1976). lb. Effects on Liver Liver Weight Dose-dependent increase in liver weight was observed in rats receiving Aroclors 1242, 1254 and 1260 at concentretions of more than 20 mg/kg in Che A-2 HONS 009990 diet (corresponding to >1.4 mg/kg body weight). Male rats were more sensitive than female rats; no effects were observed with Aroclors 1254 and 1260 at concen trations lower than 20 mg/kg in the diet (corresponding to < 1.4 mg/kg body weight). Effects were less marked with the lower chlorinated PCBs (WHO, 1976). Liver Changes Smooch endoplasmic reticulum proliferacion with fat droplet inclusions were observed in the liver tissue of rats after 8 months of dietary intake of Aroclor 1254 ac 20 mg/kg (corresponding to 1 mg/kg body weight). Liver damage was observed with Aroclors 1242 and 1254 in rabbits receiving 14 weekly orsl doses of 150 mg/kg body weight; no effect was observed with Aroclor 1221 (WHO, 1976). Liver Enzyme Activity Increase in microsomal enzyme activity was observed in male rats after 8 months of dietary intake of Aroclor 1254 of 20 mg/kg (corresponding to l mg/kg body weight). No effect was observed at 2 mg/kg in the diet (corresponding to 0.1 mg/kg body weight). Effects were less marked in female rats. Increased iceivity was also observed with Aroclors 1242 and 1016 in male rats receiving 21 daily oral doses of 1 mg/kg body weight (WHO, 1976). Liver Porphyria Effects were observed in rats after several months of dietary intake of Aroclor 1254 at 100 mg/kg (corresponding to 5 mg/kg body weight); dose-dependent effects were observed in female Tats after 21 daily oral doses of Aroclor 1252 at 20 and 100 mg/kg (corresponding to 1 and 5 mg/kg body weight); no effects were noted at less than 1 mg/kg body weight (WHO, 1976). Liver Vitamin A Reduction of hepatic vitamin A was observed in rats receiving Aroclor 1242 at the rate of 100 mg/kg in the diet (corresponding to 5 mg/kg body weight) (WHO, 1976). A-3 HONS 009991 Liver Tumors Hepatocellular carcinomas were observed in mice after one year of dietary intake of Kaneclor 500 at 500 mg/kg (corresponding to 75 mg/kg body weight); no carcinomas were observed with Kaneclor 500 at 250 mg/kg in the diet (correspond* ing to 36.5 mg/kg body weight), or with Kaneclor 300 and 400 at 500 mg/kg in the diet (corresponding to 75 tng/kg body weight). Hepatomas were observed in mice after 10 months of daily intake of Aroclor 1254 at 300 mg/kg in the diet (corresponding to 49.8 mg/kg body weight). Hepatocellular carcinomas were observed in rats after 21 months of daily intake of Aroclor 1260 at 100 mg/kg in the diet (corresponding to mg/kg body weight) (WHO, 1976). lc. Reproduction Effects on reproduction were observed in mice at a daily oral dose of 0.025 mg Clophen A60 and in the rat at a dietary level of Aroclor 1254 of 20 mg/kg (corresponding to 1 mg/kg body weight) with the effects decreasing with higher chlorinated PCBs; in the mink at a dietary level of Aroclor 1254 of 5 mg/kg (corresponding to 0.5 mg/kg body weight); and in the monkey at a dietary level of Aroclor 1248 of 2.5 mg/kg (corresponding to 0.1 mg/kg body weight). ld. Immunosuppression Immunosuppression effects were observed in the guinea~pig at a dietary level of Clophen A60 or Aroclor 1260 of 50 mg//kg (corresponding to 2 mg/kg body weight) (WHO, 1976). le. Skin Effects In man, symptoms of disease were observed at a dietary level of 4.2 mg/day of PCBs (corresponding to 0.7 mg/kg body weight/day for a 60-kg person). A value of 0.50 g was estimated as the quantity of PCBs consumed over approximately 120 A-4 MOHS 009992 days above which toxic symptoms were evident. Similar effects were observed in the monkey at a. dietary level of Aroclor 1248 of 2.5 mg/kg (corresponding to 0.1 tag/kg body weight) after several months (WHO, 1976). If. Nondetected Effect Levels The assessment of non-detected effect levels for toxic effects is com plicated by the different activities of the component PCBs and by the presence of impurities, in addition to the influence of inter-and intraspecies variation, age, sex, and length of exposure. Moreover, many of the available experimental studies do not include a non-detected effect level (WHO, 1976). The most sensitive species appears to be man, and effects have been ob served at intake rates of 4.2 mg/day. This may have been influenced by the intake of impurities more toxic chan PCBs, but similar effects have been produced in monkeys at the same order of dosage with a product containing little of these impurities. At this dosage level, no effects may be expected on growth, liver enlargement, and liver enzyme activity in less sensitive species such ss the rst. Although non-detected effect levels are not available for effects on imnunoeupprestion and reproduction, and for certain biochemical effects on the liver, it seems unlikely that these effects would be apparent at intake rates of 6 mg/day. Carcinogenic effects have been observed in rats and mice at dosages two orders of magnitude greater than this, but there is not epidemiological evidence to suggest that PCBs cause turmors in man. Rats fed a PCB diet at the rate of 2 mg/kg (equivalent to -about 0.1 mg/kg body weight) showed PCB levels of 8 mg/100 ml in blood and 26.1 mg/kg in body fat. However, values much higher than these have been observed in men occupationally exposed to PCBs without evidence of any toxic effects (WHO, 1976). 2. HUMAN EXPOSURE TO PCBs IN THE VICINITY OF DREDCE AND DISPOSAL OPERATIONS 2a. Drinking Water Residents along the upper Hudson River can be exposed to PCBs through contaminated drinking water. Hudson River water is analyzed by the US Geo A-5 HONS 009993 logical Survey at five stations on the upper reaches; Glens Falls (above the General Electric Plant), Rogers Island, Schuyierville, Stillwater, and Waterford (Tofflemire, 1980), Although the Glens Falls PCB levels are usually below the detection limit of 0.1 ug/1 (ppb), there are considerable data for the Schuyler* ville and Stillwater sampling areas for the three years beginning in October 1976. Average PCB concentrations for these years were .687 ug/1 (ppb) in 1977, .568 ug/1 (pb) in 1978, and .657 ug/1 (ppb) in 1979. Higher levels have been reported for the 1974*1975 period at Rogers Island (1.5 ug/1) and levels as high as 3 ug/1 (pb) were recorded in the Hudson prior to elimination of General Electric discharges in 1976. PCBs in Hudson River drinking waters can be reduced through treatment (Tofflemire, NYDEC, 1980). If treatment is used by comznmunities using the Hudson as a source of drinking water, levels of PCBs in finished water could be reduced from the present approximate level of .6 ug/1 to about .3 ug/1. The drinking water standard for PCB is 1.0 ug/1. Since there was no significant difference in the amount of PCB in the water for the three*year period between 1977 and 1979, theae levels probably represent background levels and residents using the Hudson for drinking water, including wells and infiltration galleries near the river, may assimilate approximately .3*1.0 ug/day at an average water consumption rate of 2 1/day. Residents with alternative drinking water supplies will be exposed to PCBs from atmospheric rain*out and fall*out into reservoirs and drainage basins, but the extent of this exposure is currently unknown. There is no evidence to indicate that these levels will exceed chose in the Hudson River. Ambient water PCB levels would increase due to return flow from the con* CainmenC site and from the dredge plume (Malcolm Pirnie, 1980). In a "worst case" scenario baaed upon clamshell dredging with hydraulic pumpout without recycle, PCB levels would increase by .8 ug/1 immediately downstream from the operation. The resulting ambient concentration of approximately 1.3 ug/1 would yield a treated drinking water concentration of .65 ug/1 and an average daily body burden of 1.3-2.6 ug/day for residents using the Hudson as a drinking water supply. This increased body burden would also apply to the modified hot spot dredging alternative although Che period of chronic exposure would be reduced. A-6 HONS 009994 2b. Food Comprehensive human food monitoring data on levels of PCBs are not avail able for the Hudson River area. Hovever, the Food and Drug Administration (FDA) conducts a comprehensive food surveillance program yearly to determine peaticide residues, PCBs, heavy metals, and other contaminants in the diets of consumers in the United States. These studies, conducted since 1969, indicate that PCBs are most commonly found in fish, both freshwater and marine, although they have also been detected in other foodstuffs (USEPA, 1976b). An FDA total diet study based on FY 70 and FY 71 data shoved composite food samples containing PCB residues of up to .36 ppm. The positive readings were found in meat, fish, poultry, dairy, and grain and cereal composites. FDA's FY 73 study included thirty market basket samples from representative areas of the United States consisting of the total 14-day diet of a 15-20 year old male (USEPA, 1976b). About 117 individual food items were analyzed. Host of the PCB levels were trace amounts. The most frequent occurrences were in the meat-fish-poulcry and grsin-cereal products groups. The range of concentrations encountered was trace to 0.73 ppm. In the FY 74 study, there were positive findings of PCBs in two food groups: sugar and adjuncts, and meat-fish-poulcry (USEPA, 1976b). Only 32 of the soples in Che first group were positive, while 452 of the second group had detectable levels of PCBs, with fish ss Che usual source of contamination. Data for 1975 indicated PCB contamination in 402 of the meat-fish-poultry samples and no positive findings in any other food groups. Based upon these data, FDA has estimated the average daily intake from all food group composites and cha average daily intake from ehe meae-fishpoulery class (Table 1). The decrease in total diet exposure is due to de creasing levels of PCBs in food packaging materials. The ingestioQ of PCBe through food should level out (based upon national background levels) and continua at the 1975 level as long as fish remain almoet the sole source of dietary PCBs. A-7 HONS 009995 Table 1. Estimates of Total Daily PCB Ingestion (FDA, 1979). Fiscal Year 1971 1972 1973 1974 1975 (1st half) Average Daily Ingestion of PCBs (ug/day) Total Diet Meat-Fish-Poultry Class 15.0 9.5 12.5 13.1 9.1 8.7 8.8 8.8 8.7 8.7 The FDA studies are based upon national data and do not reflect actual conditions along the upper Hudson River although food levels in the dredge area could not be expected to be below national averages. Monitoring of foliage near dump sites indicated PCB levels of from .1 to 58 ppm (USEPA., 1976b). Background levels were recorded beyond 700 meters from the dump sites. Since cows fed diets containing 10 ppm and 100 ppm PCBs produced milk containing 6.27 ppm and 75.4 ppm PCBs (WHO, 1976), dairy herds grazing on foliage at 58 ppm would produce milk containing between 36 ug/1 and 43 ug/1 PCBs, far above the FDA limit of 1.5 ug/l. The WHO study (1976) reports that these PCBs survive processing into dairy products, and most was located in milk fat. Foliage levels at the Moreau dredge spoil site did not exceed 1.4 ppm. Given the potential contamination of grazing land and residences near the containment site, volatilization and aerosol contamination by PCBs should be minimized prior to capping with a clay seal. Since 1975 FDA data indicate Chat the meat-fish-poultry food category is primarily responsible for dietary intake of PBCs, suspension of the ban on fishing in the upper Hudson River must be considered for its effects on local population dietary exposure to PCBs. The FDA data on fish concentrations ranged from trace to .05 ppm (USEPA, 1976b) while data on PCB levels in upper Hudson River fish indicate levels ranging from 20 ppm to greater than 500 ppm (Thomann A-8 HONS 009996 and SC. John, 1979). Recent trend analyses on levels of PCBs in upper Hudson River fish indicate that a 5 ppm level may be reached by the mid-1980s without dredging and possibly sooner if contaminated sediments are removed (Armstrong and Sloan, 1980). Temporary elevations in tissue PCS levels can be expected from increases in PCB levels in Che Hudson chat result from dredging activities. For populations along the Hudson that do not consume fish taken directly from the river, exposure to PCBs through the ingestion of food would be at least 9 ug/day, the national background level (USEPA, 1976b). Consumption of Hudson River fish with PCB levels at the FDA action level of 5 ppm would increase this amount one-hundred fold to approximately 900 ug/day (0.9 mg/day). These exposure levels would apply equally to the no action, hot spot dredging, and re-scoped hot spot dredging alternatives. Since effects on humans have been observed at 4.2 mg/day, a diet that includes up to 1 mg PCSs/dey could not be considered safe for sensitive individuals in the local population, particularly since inhalation and drinking water exposures would increase the daily body burdens. 2c. Inhalation Exposure to vapor phase or aerosol PCBs will be greatest for workers involved in the dredging and containment operations and nearby residents, and of less significance for the general population in the vicinity of the upper Hudson River. At several PCB dump sites in the Fort Edvard and Glens Falls area, concentrations exceeded the NIOSH 8 hour recommendation of 1 ug/m"*, with 3' levels at the Caputo site of up to 130 ug/m during the summer (MPI I980d). Sediment concentrations of PCBe at the Caputo site were 10,000-50,000 ppm. Workers at the Monitoring data taken near Buoy 212 during dredging in the Fall 3 of 1979 indicated atmosphere levels of .5 ug/m . The populace in Fort Edward and Hudson Falls is exposed to a general background concentration of .OS ug/m. In addition, average indoor kitchen air has been reported to be 0.32 ug/ca (USEPA, 1976b). A-9 MONS 009997 At an average working inhalation rate of 0.05 tn^/min, workers at the 3 dredge aitea could be exposed to up to 12 ug/8-hour shift (.05 m /min) (.5 ug/ra^) (60 min/hr) (8 hr/shift) 12 ug/shift) and workers at the containment site* could be exposed to 3,12 ug/8 hour shift ((.05 m /min) (13 ug/m^) (60 min/hr) (8 hr/shift) * 3,120 ug/shift) The potentially excessive exposures for containment site workers can be mitigated by personal protective equipment or by engineering controls. Residents in the vicinity of the upper Hudson will be exposed to from 0.7 ug/day to 4.6 ug/day, calculated upon inhalation of atmospheric background levels of .05 ug/m3 and indoor leve Is of .32 ug/m3 . 2d, Summary In man, symptoms of disease were observed at dietary levels of PCBs of 4.2 mg/day (WHO, 1976). Similar effects were seen in rhesus monkeys administered the same dose. Effects on liver function, reproduction, immunosuppression, skin health, and incidence of hepatocarcinomas have also been noted in various spe cies. There are insufficient data to calculate dose-response relationships for humans, and a non-effect level cannot be determined. Common contaminants associated with PCBs include chlorinated dibenzofurons and benzodioxin* (WHO, 1976). A single oral dose of chlorinated dibenzofurans of .5-1.0 mg/kg body weight caused severe and often lethal liver necrosis in rabbits. This corresponds to a single human dose of 33-65 mg for a 65 kg human. Chlorinated dibenzofurons have been circulated to be approximately one order of magnitude less toxic the chlorinated b:uzodioxins. If Che PCBs in the Hudson are - >c removed, total daily exposure to PCBs will be approximately .010-0.15 mg (9 jg from food, .3 ug from drinking water, and .7-4.6 ug inhaled). This level wii1 not change significantly during and after dredging provided the dredge spoil containment area and dredge spoil barges are covered to prevent atmospheric losses of PCBs. Without precautions, workers at the containment area could be exposed to up to 0.3 mg/day, and cows feeding on forage near the containment site could be contaminated to levels in excess of FDA A-10 HONS 009998 Haiti. If the ben on fishing in the upper Hudson River ii rescinded end these fish become e pert of this local diet, another .9 mg/day would be added to the diet. In addition to the recommended engineering controls, monitoring of the Hudson River and foliage end milk in the vicinity of the dredge end containment areas should be implemented. In addition Co analyses for total PCBs, the levels of PCB contaminants such as chlorinated benzodioxins and dibenzofurans should be monitored. Since the sediments are also known to contain high levels of cadmium, chromium, lead, and zinc (MP1, 1980d), analyses for these toxic metals should be included. The analyses should not be limited to raw river water but should be extended to include finished drinking water from treatment plants with intakes on the Hudson as well as groundwater and infiltration gallery sources of drinking water downstream of dredging and containment operations. It is unlikely that human exposure to PCBs will increase if no action is taken to remove contaminated Hudson River sediments, provided the sediments arc not disturbed by natural or anthropogenic scour. If the sediments are resuspended, increases in atmospheric, fish, and drinking water levels can be expected although there are inaufficient data to quantify the increeses and resultant human exposure. Dredging end containment operation# would not in crease human exposure significantly beyond background levels if the additional enginaering controls are implemented. Reopening of the fishery would increase human exposure to consumers of the fish by 100 fold. A-ll HONS 009999 c c fZtf- An Assessment of Risk Associated with the Human Consumption of Some Species of FishContaminated with Polychlorinated Biphenyls (PCE's) K s ,, ' " | I | June, 1979 Requested by: Donald Kennedy Cormissiorer, FDA Prepare-d by: PC3 Risl: Assessment Wcr'/. Force Joseph"FeericV.s , Cha i rnen Csputy Associate Commissioner for Health Affairs (Science) A-i2 MONS OiOOOO s / An Assessment of Risk Associated with the Human Consumption of Some Species of Fish Contaminated with Polychlorinated Biphenyls (PCB's) INTRODUCTION The risk assessment reported in this paper was conducted in connection with a pending Food and Drug Administration (FDA) rulemaking proceding involving proposed reductions in the tolerance levels for PCB's in va rious categories of food. Including fish and shellfish (Docket No. 77N-CC30). FDA has proposed, inter alia, to reduce the tolerance for fish and shellfish from 5 ppm to 2 ppm (see the Federal Register of April 1, 1377, 42 FR 17487). Most of the toxicity data on PCB's has already boan presented in this proposal. However, the available data ware not utilized for performing a human risk assessment under the conditions of various, possible tolerances; i.e., no tolerance, 5 ppm, 2 ppm, or 1 ppm PCB tolerance for fish and shellfish. Furthermore, certain data relevant to assessment of the levels of PC3 exposure and the toxicity of PCB during reproduction and lactation have been reported sinca the proposal was published; these data are also reviewed. The purpose of this risk assessment is to assist the agency in its estimation of the degree to which risk to consumers would be reduced by the proposed reduction of the tolerance for PC3's in fish. The term PCB's refers to a complex mixture of chiorobiphenyls. Commercial PCB products, manufactured in the United States exclusively HONS OlOOOl cC 2 by the Monsanto Company, are identified by the trade name "Aroclor," and tbs particular PCS as, for example, Aroclor 1254 or Aroclor 1250. The first two digits refer to the fact that the biphenyl is made op of 12 carbon atoms, and the second two digits refer to the approximate percentage by 'weight of the chlorine content in the mixture. Thus, Aroclor 1254 contains 12 carbon atoms and approximately 54 percent chlorine, while Aroclor 1250 contains 12 carbon atoms and approximately S3 percent chlorine. . ?C3's were reportedly first synthesized in 1831, but they were not commercially available until 1930 (uKIK, 1975). By late 1971, the widespread, uncontrclled use of PCS's in a variety of industrial applications had resulted in their becoming a persistent and ubiquitous environmental contaminant. Cute consequence of this environment ;1 contamination with PC3's has been the contamination of certain -cods, including fish and shellfish. Though human exposure to PCS's cccu " to a limited extent through the air and water, the most significant exposure now appears to be from dietary sources, especially from cr-sumption of freshwater fish from contaminated waters. Human breast milk is another source of these substances. ' The risk assessment reported Here uses toxicity data from animal studies, human exposure data, and a mathematical extrapolation model to arrive at estimates of risks posed by exposure to PCS's assuming HONS 010002 cc 3 the imposition and enforcement of three possible tolerance levels__5 ppm, 2 ppm, and 1 ppm. This paper will first discuss some of the toxicity data available on PCB|s. Following that will be a discussion of the calculations made regarding human exposure to PC3's through fish consumption and, finally, the results of the risk assessment. . Toxicity of PC3's A. Human Data . ' Considerable scientific interest has centered on the Yusho incident in Japan in 1953, involving human intoxication with KanachTor 4C3 [a brand of PC3's manufactured in Japan). The incident occurred as a result of the consumption by Japanese families of rice oil ("Yusho" oil) that had been contaminated accidentally with Kanechlor 400. . Tna typical clinical findings of "Yusho" disease included chlorac.ne ar.d inci eased pigmentation of. the skin, increased eye dis charge, transient visual disturbances, feeling of weakness, numbness in limbs, headaches, and disturbances in liver function. Host of the babies born to mothers 'with the Yusho syndrome were small and had skin discoloration that slowly regressed with age. Adult Yusho patients had protracted clinical disease with a slow regression of symptoms and signs, suggesting a slow metabolism and excretion of PCB's in humans, probably resulting from a long biological half-life. A total of 1291 A-15 HONS 010003 cc 4 Yusho disease cases have been reported up to May, 1975 (NICSH. 1977). Originally, the effects seen in the Yusho incident were - attributed exclusively to PCB's, which had been thought to be the sole contaminant of the rice and had been identified in the blood and . tissues of Yusho patients. In the review by Kuratsune et al_. (1975), a new factor was introduced: the canned rice oil was shown to be contaminated also v/ith polychlorinated dibenzsfurans (PCDF's) to the extent of 5 ppm. In addition, Kuratsur.a presented data of iiagayena et _al. (1975) showing PCDF's to be present in the liver end adipose tissue of Yusho patients, while none was found in that of a control group. The ratio of PC3's to PCDF's in the Yusho oil (containing "used" Kaneehlor 400) was 200:1, whereas the ratio of PC3's to PCDF's in "unused" (unheatad) Kaneehlor 400 is 5C,OOC:T. Thus, with respect to PCS's, the ratio of PCDF's in Yusho oil to.PCDF's unused Kanechlcr 100 is 250:1. Also, the toxicity of PCDF's ranges from ZOO to 500 times that of PCS's (Cordle et al , 1973). Thus, fer egual amounts of rice-oil and pure Kaneehlor 400, the toxicity of the rice oil would ranga from 2 to 2.5 times that expected frem its PCS content alone. Uncertainty about the confounding of effects between PCS's and PCDF's makes it difficult to determine from the Yusho data exactly what effect(s) exposure to only PCB's could have on humans. Detailed A-16 MONS 010004 Lt 5 records of the 1291 Yusho patients have been maintained in an effort to detect possible long-term effects. At least.? out of the 29 deaths that occurred as of May,' 1375 have been attributed to malignant neo plasms (f.'IOSH, 1977), but a causal relationship between PCB's and cancer cannot be inferred because of the confounding introduced by the presence of PCDF in the oil. The Yusho study, nevertheless, can lead to two important observations: first, PCS's can be transferred from mother to fetus and from mother to child through breast feeding; and second, highly chlorinated PCS compounds are excreted more slowly from the body than the less chlorinated ones (NIOSH, 1977). finally, in a study of chemical workers (Eahn _et _al_., 19.76, 1977), two malignant melanomas were diagnosed in 31 workers exposed heavily to Arochlor 1254 (anj also exposed to other chemicals that could possibly cause cancer). It was estimated that .04 malignant melarcmas would have bean expected from this group of individuals. Among 41 other workers also exposed to Aroclor 1254, but less heavily, ona additional malanoma was diagnosed. '` Data from Lifetime Animal feeding Experiments A number of studies have evaluated the neoplastic potential cf PCS ingestion (Ito, 1373, Linder et_ aj_., 1974, Kimbrough et c_l_., 1973, 1974, 1975, Caiandra, 1975, NCI, 1978). Each of these studies A-17 HONS 010005 cc provides some evidence'that neoplastic lesions can be induced by PCS .exposure. However, only three of these were of-sufficient duration to be of value in assessing the lifetime carcinogenic risk of PCB's. These three studies are the following: 1) Effect of Aroclor 1250 on Female Shaman Rats Thimbrouch et al., l9?a) In this study, 200 Sherman strain female rats were fed a diet containing ICO ppm of Aroclor 1250 for approximately 21 months, end treatment was discontinued for 5 weeks before the animals ware sacrificed at 23 months. A group of 200 untreated female rats served as controls. All animals were observed daily; moribund animals were sacrificed and subjected to gross and microscopic pathological examir.a-.ion, as were the animals sacri ficed at the end of tha experimental pariod. A total of 134 dosed rats and 173 controls survived to the end of the experi ment. Tha authors concluded the*. Aroclor 1260, whan fed in the diet, had a hepatocarcinogenic effect in these rats. Ho.signifi cant differences could be observed between experimental and control animals with regard to the incidence of tumors in other organs. . Although this study provides strong evidence of the carcinogenic potential of PCB's. certain prtocol design elements preclude this study from being considered adequate by today's A-18 HONS 010006 c c7 standards. These deficiencies include the use of only female rats; lack of in utero exposure in the light of evidence that suggests in utero effects; sacrificing the'animals at a rela tively early time of 23 months, considering the expected life span of 25-30 months; and continuing dosing only up to 21 months. However, these shortcomings would, if anything, tend to mask or understate the true carcinogenic potential of PCB's. 2) National Cancer Institute (1978) Bioassay of the Carcinogenic effect of Aroclor 1254 in Fisher 344 Rats 3 - ' In a bioassay of Aroclor 1254 (National Cancer Institute, 1978), groups of male and female Fisher 344 rats (24 of each sex per group) were administered the test compound in the diet at 25, 50, and 100 ppm for a period of 104-105 weeks. Hatched controls consisted of groups of 24 untreated rats of each sex. All ani mals 'were observed daily for signs of toxicity and palpated for tissue masses at each weighing. Moribund animals were observed daily for signs of toxicity and palpated for tissue nas'ses at each weighing. Moribund animals were sacrificed and subjected to gross and microscopic pathological examination, as were the ani mals sacrificed at the end of the experimental period. It was concluded that "under the conditions of this bioassay, Aroclor 1254 was not carcinogenic in Fisher 344 rats; however, a high incidence of hepatocellular proliferative lesions in both male A-19 MONS 010007 GC 8 and female rats was related to the administration of the chemical. In addition, the carcinomas of the gastrointestinal tract may be associated with the administration of Arcelor 1254 in both males and females." Although Arcelor 1254 v/as not shown to be carcinogenic by the NCI bioassay, it must be kept in mind that this was a relatively small experiment utilizing only 24 animals per dose group per sex. Tc provide statistical sensitivity for detection of cancer, the usual number of animals par group for an NCI bioassay is 50. A likely reaper. this bioassay is smaller than most may be because this study '-.-os pa"t of a larger study designed to assess the combined effects of a group of chemicals. Overlooking for the moment the net that the protocol s were different than those user for a standard cancer bioassay and different Aroclors were . tested, the results of the NCI bioassay and the Kimbrough study are not entinly '"neonsistent. Both studies indicate that the liver is the ta-get organ for toxicity, and a high incidence of proliferativa lesions occurs in both studies. Furthermore, if the same percentage of animals exhibited carcinomas in the NCI Study as in the Kimbrough (1975) study, the high dose (190 ppm) group in the NCI study would exhibit only 3 carcinomas out of the 24 animal s/sex used in this study. (This compares closely to the 2 carcinomas the NCI study found in this dosage group.) A-20 HONS 010008 c 9 Nevertheless, due to the sea'll number of animals in the NCI study. It is not presently possible from the NCI bioessay data to support either a carcinogenic or noncarcinogenic response with PCB's in Fisher 344 rats. 3) Industrial Bio-Test Experiment (19711 with Charles River Rats ~ This experiment was performed by Industrial 3io-Test Laboratories (1971), and a summary of results was presented at the National Conference on Polychlorinated 3iphenyls (Calandra, 1575). On? thousand Charles River strain albino rats were placed into 10 treatment groups. One hundred rats (50 male ar.d 50 female) served as controls and 100 rats (30 mala and 50 female) were assigned to each of nine treatment groups which were fed diets containing 1, 10, and 100 ppm of A,-odors 1242, 1254, and 1260, respectively. Dosage started when the animals ware about 4-6 weeks old and continued for 24- months. The liver slides from this study have been examined twice by pathologists, cr.ce in the original report (Industrial Bio-Test Laboratories, 1971) and in a later report (Monsanto, 1975). The diagnoses in these two exam inations were disparate, e.g., for animals dosed at 100 ppm, the first examination diagnosed one hepatoma and two animals with nodular hyperplasia, whereas the later examination diagnosed A-21 HONS 010009 k i-.m t l ,- i----------------------------------- 1-------------I.:.. - -. . . ...........*,.*.*>*.,**------ ................................... ! cc elevan animals with hepatomas and twenty-eight animals with nodular hyperplasia. . io For unexplained reasons, there was also unusually high mortality among the rats in the experiment, and the numbers of rats were further reduced by interim sacrifices during the course of the experiment. , For example, only 6-21 animals out of the initial 100 in each treatment/sex subgroup fed 100 ppm survived to the terminal sacrifice. The FDA has found many such abnor malities with work conducted by Industrial Biotest Laboratories and has disqualified this study as a valid carcinogenic study and considers the findings unreliable. Nevertheless, re-diagncsis of. the liver pathology indicated a significant tunorigenic effect. The incidence of nodular hyperplasia was significantly elevated in the group fed 10 ppm Aroclo' 1250 over the incidence in the control group. Tr.ere are a total of 9 hepatomas in the groups fed 100 ppm of one of tha three .-roclors, but none in the groups fed lesser concentration cf OCE's. Because this study is consid ered unreliable by the agency, ;t will not be used for estimating risk, but is presented as supportive data only. Examination of the literature available on PC3 toxicity Indicates various types of toxicity other than carcinogenicity. A-22 HONS 010010 cc 11 Tliese toxicities Include teratogenesis, reproduction effects, behavior effects, skin disturbances, edema, etc. This report is not ignoring these effects but is addressing only estimated human lifetime risks to canter and not each of the other reported toxicities. Certainly, data fcr all types of toxicity will be considered in assessing the overall safety of PCS's in the diet. <) Additional Toxicity Data _ A recent presentation of Barsotti et _al_. (1979) indicates that female Rhesus monkeys exposed to PCB's exhibit reproduction and neon atal toxicity in their offspring even after PCB exposure has been discontinued for over a. year. Details of this study were provided to us by Dr. J. P.. Allen (1979) in the form of a draft scientific paper. Aroclor 1243 (PCB) was fed to eight female Rhesus monkeys . at levels of 2.5 and 5.0 ppm in the diet. After six months, they were mated to control males. Six of eight females fed at 5.0 ppm conceived but only one was able to carry to term. Most of the abortions . occurred during the first 45 days of pregnancy. All of the animals fed at 2.5 ppm conceived and five gave birth. During nursing, milk PC3 levels were 3.35-9.9 ppm (on a fat basis). Viithin tvio months following birth, the infants had facial acne and edema, swelling of the eyelids, loss of facial hair including eyelashes, and hyper- A-23 HONS OlOOU L- 'i- . 12 pigmentation of the sk.in. Tnree of the six infants died during their first year of life due to PC3 intoxication (Allen, and Barsotti, 1976). . To evaluate the prolonged effects of PCB's on adult female primates, the PC3-containing diets ware discontinued for approximately one year and the females were again mated to control males. No con trol female to control male matings were performed. All the females conceived. Four of the seven 5 ppm animals gave live births while seven of the eight 2.5 ppm females gave live births and one had an abortion. At birth, the infants from the 5.0 ppm group were generally smaller than the historical control infants.. The 2*5 ppm infants showed considerable weight variation. O During the four months of nursing, the infants of both groups developed h/per;:fomentation about their hairline. Analysis of the milk that the infants wera consuming at the time they were weened revealed FCB levels of frem 0.9 to 1.25 ppm (on a fat basis) compared to 3.35-S.3 ppm previous to discontinuing PC3 treatment. Two infants from each group died following weaning. Prior to death, these infants became anoretic, lost weight, and developed swollen eyelids, loss of eyelashes, scaly skin, acne and alopecia (all signs of PCS poisoning). . A-24 HONS 010012 ' It can be cb..c*r\.ded that one and a half year5"a t.er exposure to PCa's and with the milk PC8 levels considerably reduced from previous levels, there was enough PCB in.the milk to increase the body burden in the infant and cause PCS poisoning. It should be noted that during the time the females ware off the PCS diet there had been a dramatic decrease in the PCS content of the subcutaneous fat of the adult animals. Nevertheless, when these animals were lactating, the PCS content of the milk fat had changed less dramatically than expected from adipose tissue levels. These data suggest that during lactation, PCB's are concentrated in the^milk fat and accumulate in infants to levels higher than in their mothers. A study by Kuwabara et__al_. (1973) presents convincing human evidence that brest-fed, children of mothers exposed to PC3`s have much higher blood PCS levels than controls. Furthermore, the blood levels in children who breast feed for greater thar three months ware higher than their mothers. A correlation between duration of breast feeding and blood levels was shown. These data are presented in more detail under e subsequent section of this document on Human Milk exposure to PCS's. ' '. In conclusion, these newly reported data present the agency with a difficult task in protecting the unborn and newborn young. At the r present time, we are unable to assess the long-term risk from Increased exposure to PCB's during a relatively short part, e.g. (six months to one year) part of the total lifespan of an individual. Ordinarily, adequate protection from such effects can be attained for children and adults if a level of toxicant producing no observable A-25 HONS 010013 14 adverse effects, Is determined; however, the data available do not permit establishment of such a "no-effect" level in monkeys. Furthermore, because the infant is undergoing tremendous growth and differentiation during this period, it is possibly even more susceptible to PCS intoxication than is the adult. Estimated Human Exposure Levels A. FDA Total Diet Program . Using the FDA Total Diet Program data (Johnson and Manske, 1977), an estimate of PCS exposure from all dietary sources for 1974-1975 was compiled (Jel trick and Corneluissen, 1975). These values, which are listed in Tables 1 and 2, must be viewed as only crude estimates since in order to obtain them numerical values had to be assigned to trace observations. Tnose levels that were reported as trace were con sidered to be at one-half the quantitative lowar level of detection, i.e., .025 ppm. Examination of Tables 1 and Z indicates that the predominant food class in which PC3's were detected from 1974 to 1S77 was meat, fish, ar.d poultry. The majority of thase positive findings art dua to PC3`s in fish samples. It appears from Tables 1 and 2 that the average daily PCS intakes from the meat, poultry, and fish cate gory have remained fairly stable (7.9 - 9.1 [g/day) since 1972, whila levels in other foodstuffs have decreased to nondetectable levels. A-26 HONS 010014 i___ 15 B. PCB Levels In Fish . As pointed out in the previous section, the most significant exposure to PCS's in food is through fish. Tables 1, 2. The distribu tion of total coraiercial fish consumption can be calculated from the Seafood Consumption Study (National Karine Fisheries Service, 197S), but the distribution of consumption of other freshwater sportsfish species is not available. Moreover, the concentration of PCB's in fish is highly variable, both among species and within a single spacies. Fish caught further offshore tend to have smaller amounts of PCS's than estuarine fish, and freshwater fish caught in areas of high PCS pollution tend to have the highest concentrations of PCS's. Furthermore, sports fishermen would consume varying amounts of fish. The activities of sports fishermen are not end cennot be regulated by the FDA. ' ,, 1) Estimate of Human Exposure to PCS's Through Commercial Fish Consumption ! '! 1." order to determine human-exposura to rC3's through commercial fish, it is necesary to know the levels of PCB res*i dues in the edible portions of fish consumed by the population. Information has been compiled by the National Marine Fisheries Service-NOAA (1975) on the most important types of fish in the U.S. diet and on the mean daily amount of each type consumed by those who actually consumed that type. This study included 25,907 eaters selected as a sample representing all fish eaters in the United States. ' A-27 HONS 010015 16 Information from the survey shows that some twenty species comprise 95S of all the fish products eaten. Although 932 of the U.S. population (197 million) eat fish, the average annual per capita consumption of fish is small: 15.0 Ib/year. A major portion of total consumption consists of "unclassified" fish, ranking just below tuna in importance. This "unclassified" fish consists of a variety of species, each of which considered separately would make up only a minor portion of the diet. Freshwater species, led by trout, bass, and catfish, comprise about 9% of our total fish diet. Table 3 lists the 12 fish categories of interest, i.e., the 11 species of fish found in the FDA 197S-IS79 survey to have the highast PCS residua levels and all other species grouped ' under "all other," and gives the mean PC2 levels in these species assuming the absence of an FDA tolerance and assuming the imposition of tolerances of 5 ppm, 2 ppm, and 1 pp~. A rough ' approximation of the.effect of a given tolerance on mean PC3 levels for each species was arrived at by eliminating samples with PC3 levels above the assumed toleranceand recalculating the mean. A-28 MONS 010016 r 17 Table 4 lists estimated human exposure levels corresponding to no tolerance, and tolerances of 5 ppm, 2 ppm, and 1 ppm for those 3339 persons who ate the species of interest. Because analytical methods for regulatory purposes are hot presently available for PCS levels below 1 ppm in fish, (i.e., due to analytical limitations, it would not now be possible to impose a tolernce at levels less than 1 ppm) no exposure estimates were made for levels below 1 ppm. The estimated daily exposure levels were arrived at by multiplying the consumption per day of each of the species of interest (at both the 50th and 90th percentile consumption levels) by the mean PC3 level for each type of fish assuming no tolerance and tolerance levels of 5 ppm, 2 ppm, and 1 ppm. The figures in Table 4 reflect the total estimated daily exposure frcm the 12 species of interest. The risks estimated on * ' tha basis o' these exposure levels can be extrapolated to the 15.2% (3939/25947) of the total U.S. population expected to consume the species of interest. . Tha estimation of mean PC3 levels in fish assuming no tolerance and tolerances of 5 ppm, 2 ppm, and 1 ppm is a key ele ment of tha exposure estimates and may be the most uncertain part of the entire risk assessment. The effect of a given tolerance on the mean PCS levels depends to a large degree on the actual distribution of PC3 levels before a tolerance is instituted. The data used here consisted of 892 samples collected in 1978 and 1979 from all of the PDA districts. This sampling may not have A-29 MONS 010017 V. 18 been sufficiently representative or extensive to provide a reli able estimate of the distribution of PC3 levels in each species. It should be noted that the mean PCS levels based on an assump tion of no tolerance may not reflect all PCS levels occurring in fish because the 197S-1979 survey was carried out when a toler ance of 5 ppm was in effect. Thus, the effect of going from no tolerance to a tolerance of 5 ppm may be greater than shown here. 2) Estimated Sports Fisherman Exposure to PCB's from Sports fish Consumption ' The National Fish and Wildlife "onitoring Program has followed PCB levels in freshwater fish for many years. Walker, 1976; summarized these findings ar follows: "Geographically, the higher concentrations appear to ' be associated with certain r'iver systems having industrial activity.... PC3 residues expressed as Aroclor 125>! 'were found in five major river systems in the Atlantic coastal region, with residues exceeding 5 mg/kg. Four of these stations had residues exceeding 10 mg/kg during the last 5 years. 'Fish in four of the Great Lakes stations had PCS concentrations exceeding the 5 mg/kg level and all stations reported concentrations exceeding 0.5 mg/kg. In the A-30 HONS 010018 Mississippi River system, the Alleghany and Ohio were the hot spots, with seven out of the eight stations reporting residue concentrations in excess of 5 mg/kg. Thirty-ona of thirty-five stations in this river systen reported residues in excess of .15 ng/kg in the 1973-73 sampling programs. The highest residues, often exceeding 10 ng/kg, were found in the Allegheny, Kanawha, Cumberland, Tennessee, and Ohio Rivers along with stations on the Mississippi River at Memphis, Tennessee, and the Missouri River at Herman, Missouri. Other monitoring stations that were found to have residue levels exceeding 3 mg/kg during the sampling periods 1970-73 included: the Williametts River on the Columbia system; the Rouge River in the Pacific coastal drainage; the Sacramento River in California; the Chena Rive1" tributary of the Yukon in Alaska; and the Rio Grande, Alabama, and Mississippi Rivers in the Culf States region. Only in two sample periods of 1972-73 and in the current monitoring samples, which are still yet to be fully analyzed, has there been a downward trend, but this occurs only in those samples where residues are not being detected. The stations where high residues have been noted in the past still remain rela tively contaminated with PC3. unlike the decline of DDT in Great Lakes fish, PCS- concentrations do not show significant changes and may trend upward in salmonids........... " a-31 MQNS 010019 e 20 Both the Hudson River (Spagnoli end Skinner, 1977) and Lake Michigan (Humphrey _et l_., 1976) have exhibited PCB levels in their sportsfish that were very high and in seme cases still increasing. The Michigan Department of Public Health recently completed a study (Humphrey, H.E.B. et_ al_., 1975) which attempted to assess seme of the consequences of human exposure to RGB's from the consumption of sportsfish caught in different areas of Lake Michigan. The study included exposed and control subjects from five areas of Michigan bordering on Lake Michigan. Exposed study subjects v/ere those individuals who censured at least 24 to 25 lbs of Great Lakes fish per year. - Control subjects were those individuals who consumed less than 6 lbs sf Great Lakes fish per year. An assessment of the findings in the study indicates that the most frequently recorded quantity cf fish consumed by the study participants was in the 24-25 Ib/yr range. Tine highest recorded fish consumption over the two-year period of the study was 130 Ib/yr, and the highest single-season consumption was 250 pounds. Mean PCB levels in whole lake trout are reported as 18.93 ppm in 1973 and 22.91 ppm in 1974; and in coho salmon, as 12.17 A-32 HONS 010020 21 ppsi in 1973 and 10.45 ppm in 1974. However, comparisons of PC8 levels in raw vs. cooked fish indicated that actual human expo sure to PCB's from fish consumption was less than might be expected from the raw fish data. This is because preparation (trir.ming away fatty tissue) and cooking result in a decrease in the amount of PCB's remaining in the fish at the time it is consumed. For example, the PC3 level in cooked lake trout consumed by the study participants ranged from 1.03 ppm to 4.67 ppm; in cooked salmon from 0.43 ppm to 5.33 ppm; and in other cooked fish from 0.35 ppm to 2.06 ppm. These levels are decid edly lower than the level of PCS contamination reported in raw trout and salmon. - PCB's.were found in all blood specimens collected from the 182 study participants during the study pariod, including controls. The values ranged frcm a mean of 0.C07 ppm in blood in the control group to a mean of C.35S ppm ir, the exposed group. Although there was a wide range of blood values for each quantity of fish consumed, there was a highly significant corralation between the reported quantity of Lake Michigan fish consumed and the concentration of PC3's in the blood of study participants. No annual variation in PCB blood levels in humans could be demonstrated. The mean PCB blood values for the control' and exposed groups did not appear to change rarkedly from 1973 to A-33 HONS 010021 l ------------------ - -- --------------------------------------------- --------------------------- -- 22 1974. In addition, abstinence from Lake Michigan fish '' consumption for a period of 90 days or more did not change the PCS blood levels significantly. PCS blood'levels over the abstaining paricd show variations, but no steady decline. In fact, more subjects showed no change or a rise in PCS blood levels than showed a decline during the period of abstinence. The calculated quantity of PCS's ingested by eating Lake Michigan fish averaged <6.5 mg/yr and ranged from 14.17 to 114.31 mg/yr. The calculated mean daily dose received by the exposed group in the study was 1.7_g/kg/day and ranged from 0.03 to 3.94 ^ijg/kg/day. PCB ingestion for each Individual was determined by proportioning his/her reported annual fish consumption by fre quency of species eaten and the cooked fish PC8 levels for those fish. The community average for cooked fish was use! in instances where cooked fish determinations were not available for a study participant. Because fish consumption was found to vary from year to year, the average annual consumption for each indi vidual for the two baseline years of study was used in each case. The exposed group experienced no observable adverse health if' effects or symptoms as a result of their exposure. Though this study suggests that the PCB consumption and blood levels observed ------- - A-34 HONS 010022 U 1: 23 In the study are not high enough to trigger the adverse effects experienced by the Yusho population, it does not preclude the possibility that such levels caused effects too subtle to detect or effects whose latency periods exceed the period of the study. One subject in this study gave birth to a normal child in January, 1975. A milk specimen from this individual contained 4 ppm PCS (on a fat basis), whereas the blood PC8 level was 0.Q53 ppm. , C. PC3 Exposure From Human Milk A nationvn'dc- survey for levels of PC3's in human milk covering 44 States was conducted by Sevag? (1577). He examined 1033 samples and detected PC3's in all but S cf the samples. Of the positive samples, 720 had trace amgunts end 3Q9 had levels that ranged from 0.03 ppm tr 13.92 ppm (fat basis). A total of SI samples (7.3f.) had PCB levels that vie re in excess of the present 2.5 ppm. (fat basis) temporarytolerance used by PDA for comme-cial milk. The mean PC3 concentration for ell the samples was estimated to be in .the range of I.00-1.10 ppm (fat basis). Although only one data point is available for PC3's in human milk from a Michigan fish consumer, this level is quite high (4 ppm on a fat basis). It teems reasonable to assume that since this woman was an average sports fish consumer, a sizable number of the woman in A-35 HONS 010023 r, {- Michigan who con5*...w sports fish could produce mis, cnat has four 24 times (4 ppm vs. 1 ppm) the averge U.S. levels of PCB's. The same may be true for other states in which sports fish consumption is similar' r to that of Michigan. . A recent study (Kuwabara et _al_., 1978) examined the relationship between breast feeding and PCS levels in the children of mothers occu pationally exposed to PCS's. The children had ingested their mothers' milk for 0 to 3 years. The age of the children was 0-13 years. Con trol subjects, Yusho patients, and occupationally exposed mothers were studied for PCS blood levels art had 2.5 +_ 1.2, 4.2 +_ 1.9, and 36.8 21.5 ppb, respectively. The children of the occupationally exposed mothers had PCB blocd levels of 14.3 18.1 ppb. Thus, these children had PC3 bleed levels that were at least 3 times higher than were blood levels in Yusho patients. Close examination of 59 of these children indicates that the determining factor in the children's blood level was the length of time that the child oreast fad and not the acs of the child when the blood levels '..ere determined. Thus, blood levels in children'who fed on artificial milk-is much lower than that of their mothers' (mothers 45.3 +_ 23.5, children*5.8 +_ 5.8); children who breast fed less than three months had moderate blood levels (mothers 35.5+_ 19.3, children 12.5+6.9 ppb); and children who breast fed for greater than three months had higher blood levels than their mother (mothers 21.9 +_ 13.4, children 32.S +_ 33.3 ppb). These results suggest that the PCB blood levels in children are much mora a function of PCB from mothers' breast milk than placental transport during gestation. The authors further estimated that the expected A-36 MONS 010024 .c C 25 exposure for adults having no-occupational exposure was 20jjg/day (0.33yjg/kg/day) while children of occupationally exposed mothers would have been exposed to 500^Jg/day if their mothers' milk had-0.5 ppm PC3's and they consumed 1 kg milk/day. No overt toxicity was reported in the children. Risk ASSESSn-NT ' 5ecause of the lack of sufficient human data, risk assessments for potential long-term toxic effects of ?C3's must be made on the basis of animal experiments. In the absence of contradictory kinetic or metabolic data, animal data are appropriately used to estimate potential human risks. Because the numbers of animals used in tests are limited, doses above the human exposure levels are used in animal studies to increase,the probability of detecting potentially toxic chemicals. Thus, it is necessary to estimate the risks to humans at low doses by use of statistical extrapolation. Because of the inabil ity tc observe the low end of the dose-response curve with precision, the Interagency Regulatory Liaison Work Group on Risk Assessment (1979) has recommended the use of-linear (or when -necessary, one-hit) - extrapolation from high to low doses. Cf the available methods that appear to be consistent with what is known about the biological mecha nism of carcinogenesis, the linear method is the least likely to underestimate risk. Also, linear extrapolatio.n is the limiting case for the multi-stage model of carcinogenesis at low doses. Because the shapes of dose-response curves at low doses are unknown, actual estimates of risk are not possible. 8ut, based on plausible A-37 HONS 010025 C: c 26 assumptions, it generally is possible to place upper bounds on potential human risk by use of linear extrapolation based on animal data. The linear method is.used here. Upper S9i confidence bounds on the animal response data are used to eliminate the effect of sample size so that comparisons between experiments can be made. Use of such upper bounds adds an additional degree of conservatism to- the estimate. The extent to which these estimated risks reflect true human risk is always uncertain. In the case of PCS's, tha uncertainty is greatly compounded by tho absence of toxicity data on the particular set of FCS's that occur as residues in fish. Due to environmental transfor mation, the PCS residues found in fish are of a chemically different composition than any of the industrial PC3 products, though a typical PCS residua in fish resembles the Aroclor 1254 mixture more closely tkjn it does ocher Aroclors (Zitke et_ a_l_., 1572; Veith, 1975). All the animal toxicity data represent the "effects of one of the indus trial PCS products; r.o toxicity studies have been performed using the ' PC3 residue that actually occurs in fish. For this reason, it is uncertain that tha available toxicity data accurately represent the toxicity of the PCS mixture ingested by humans who consume fish. The fairly close resemblance of such residues to Aroclor 1254 permits some reliance to be placed on data derived from studies of that PCS product, but the chemical difference between even that product and actual fish residues introduces an additional element of uncertainty into the risk assessment. HONS 010026 A-38 cc 27 Data from the NCI bioassay program in which Aroclor 1254 was fed to Fisher rats are presented in Table 5 to show the numbers of total malignancies, liver carcinoma plus adenomas, and hematopietic effects in rales and females at various feeding levels. Similar data are also presented in Table 5 for the feeding studies of Kimbrough using female Sherman rats fed 100 ppm Aroclor 1260. Eased on the toxicity data in Table 5 and the exposure data in Table 4, the upper confidence limits (99) on lifetime risks for career in eaters of the 12 fish species of commercial interest at the . 50f.h and 90th percentiles of consumption have been calculated and are presented in Table 6. In addition, the lifetime risk for consumers of soortsfish in Lake Michigan at the 50th and 90th percentile of con sumption are presented. These risks would probably approximate those O c." sptrtsfiib consumers in other areas of the country having PCi contamination, but for which residue data are not available. Upper limits cm estimated risks have been computed from the NCI data on total malignancies for male's plus females, liver carcinoma plus adenomas in males plus females, and on hematopietic in males plus . females, estimated risks similarly computed from the Kimbrough data are also presented in Table 6. The various estimated risks shown are based on mean PCS levels in commercial fish, assuming no tolerance, a tolerance of 5 ppm, 2 ppm, and 1, ppm. Risk for sports fishermen was HONS 010027 only calculated assuming no tolerance, because tolerances have no relevance to such exposures. Because the relative susceptibilities of humans and test animals to the chronic effects are unknown, it is not certain whether tha data in Table 6 over- or underestimate human that the various rat strains used react similarly to PCB carcinogenic insult. The relative effects of exposure reduction can be seen and increased risk associated with sportsfish consumption in Michigan (and, presumably, in other areas having similar contamination problems) is apparent. Multiplication of the size of the population at risk by the risk estimates found in Table 6 yields the number of extra cases of carc'noma per year; these data are presented in Table 7. The assumption was made that the risk is evenly distributed over a 70-year lifetime. A tolerance of 5 ppm appears to reduce cancer risk about 3-1G5 from that expected with no tolerance; a tolerance of 2 ppm appears to reduce risk about 22-325, and reducing the tolerance to 1 ppm appears to reduce risks to 55-615 of the cancer risk expected in the absence of any tolerance. Furthermore, the Lake Michigan sports fish con sumers have a 12-14 fold increased risk compared to the general U.S. population. It should be noted that the possible human risks due to the effects of PCS's on the reproductive system and offspring cannot be ignored. Exposure to FCB's from human milk also imposes an additional burden on the infant, which burden has yet to ba assessed. Certe-'nly, the infant who is breast feeding will consume higher levels cf ?C3's/kc/day than the general population. Added to the nationwide human milk PCS burden would be the increased levels of PC3's that would occur in the milk of consumers of sportsfish. A-40 HONS 010028 C 29 Estimating risk from exposure during gestation and neonatal ' growth is very difficult. The toxicological data have not been developed, and the methodologies for computing life-time risks from exposure to a substance only during a short period of life have not been developed. It is reasonable to predict that children exposed in such a fashion may suffer an increased cancer burden from PCB's, especially if dietary contamination continues after childhood and throughout life; thus, the risk estimates shown in Table 6 may underestimate risk in years to come. A-41 HONS 010029 HONS 010030 L.L -'V'. yh'.M-y.f'i Mlill'iiUtilr **.l iw-^lditlkMFMk^ ' rtUv. ___i./.e J ,: T.J Table 1: Total Diet Studios-Amerlcan Teenage Kale Percent oTT-/rapesites containing PCS'TsT Food class composites -J Fiscal Year Dairy pro ducts Heat, fish a pool try Grain .' cereal products Potatoes l.egume vege tables Root vege tal)! es Garden A fruits Oils, fats . short ening Sugars and adjuncts n/i 1972 1973 . 1974 1975 (1st half) i 6 10 47 46 33 ' 43 40 . 13 6 17 . Source: Jelinek and Corneliussen (1976) 3 633 17 6 3 3- A- . Table 2: Estimates of Dally PCB Intakes (Total Diet Study-Teenage Male) Fiscal year Average Daily Int ake of PC8'sa Total diet (ug/day) Meat-fish-poultry food class (ug/day) 1971 1972 . 1973 197C 1975* 1975* M/7* 15.0 12.6 13.1 8.8 8.2 8.5 ' 8.7 ' 9.5 9.1 8.7 8.8 8.2 7.9 8.1 *Lowar limit of quantitative reporting = 0.05 ppm with analytical methsd employed. Meline!: (1373) personal ccmunication. . .. A-43 HONS 010031 Table 3: Mean PCS Levels In FDA 1970-1979 Domestic Survey by Species of Interest Species of Interest Carp ij w Catfish . Buffalo Freshwater Trout Sea Trout Bass Chubs Bluefish Scup (Porgy) x J Drum o 5 Mackerel o All Others Assuming No Tolerance* Mean (ppm) N 1.10 1.70 54 295- 0.50 36 1.36 0.56 07 10 1.20 15 1.14 0.53 19 23 0.72 10 0.49 12 0.53 21 0.26 206 Assuming 5 ppm Tolerance . Kean (;ipm) N 0.90 52 119 201 0.50 36 1.20 05 0.56 10 1.20 15 1.14 0.53 19 23 0.72 10 o 19 12 0.53 21 0.26 205 Assuming 2 ppm Tolerance Mean (ppm) 0.60 N 46 0.73 219 . 0.43 35 0.76 ' 0.56 50 10 0.77 11 0.96 0.44 17 22 0.72 10 0.49 12 : 0.53 21 0.24 204 Assuming 1 ppm Tolerance Mean (ppm) N 0.54 30 0.30 \ 150 0.30 31 0.37 0.27 0.27 40 0 10 0.50 0.37 9 20 0.53 8 0.32 10 0.20 17 0.22 201 HONS 010032 `For assumed tolerances, PCD values exceeding the tolerance were ellrnintcd in calculating the mean. A-44 Table Intake of PCB's from Fish for Eaters of Soccics of Interest (3039/25,947) Assuming* No Tolercr.ce Assuming Tolerance n 5 ppm Assuming Tolerance =* 2 ppm Assuming Tolerance = 1 ppm Intake at 50th percentile ug per day PPM of diet** ug per kilogram of body wel glit Intake at 90th percentile ug per day PPM of diet ug per kilogram of body weight*** 0.46 .0056 .12 22.1 .0147 .32 7.57 .0051 .11 5.59 .0037 .00 3.30 ` .0022 .05 <. . 20.1 , 14.9 . .0135 .29 .0099 .21 9.22 .0061 .13 * for assumed tolerances, PCB values exceeding the tolerance were eliminated ** Assumed 1500 grams daily Intake w (/> o * o o U> w A-45 ar tV Table 5: Animal Data Used for Risk Extrapolation to Humans Dcse of Aroclor fed in ppm Animal Studies 0 25 50 100 HOI Sicassay - Fischer Rats fed Aroclor 1254 Total Maiig-aties Males Femmes Combined 1 1 Cardnoma 0 Adenomas Males Females Combined 5/24 4/24 9/43 C/24 0/24 0/4? 2/24 13/24 15/43 0/24 0/24 0/42 9/24 5/24 17/43 1/24 1/24 2 '42 12/12 9/24 21/4S 2/24 2/24 1/48 Males Fer.al es Combined 3/24 4/24 7/4S 2/24 E 31 5 -i 5/24 5/24 11/43 0/24 5/24 15/43 Kimbrough - Female Sherman Rats fed Aroclor 1253 Keoatocellular Carcinomas 1/173 26/124 A-46 HONS 01003* u^11r>vw>v i Mra* ia.vt Table 6: Upper Confidence limits (593) on lifetime Risks* of Cancer in Caters of fish Species of Interest Animal Studies on which risks are based -Kimbrough - Rats Liver Carcinoma SO til 'Yrcont i ]p Caters Assuming No Tolerance ' Lake** ' USA Mi chi pan Assuming Assinuiny Assuming lolerance Tolerance Tolerance = 5 ppm " ? I'!' = 1 npm 90th 'ercenti le Eaters Assuming Nu tolerance Lake** USA Michigan Assuming Asr.umincj Assuming tolerance Tol JTiince Tolerance = 5 ppm - 2 ppm = 1 ppm 1.3 18.4 1.2 0.8 0.5 3.4 41.4 3.1 2.3 1.4 NCI flioassay - Total Hallynancies for Male .'. female 4.1 58.0 3.7 2.7 I.G 10.6 120.2 9.8 7.2 4.4 NCI llinassay - Liver Carcinoma i Adenomas for Male A Female O.D 12.75 0.0 O.G 0.4 2.5 30.5 2.3 1.7 1.0 (ICI llio.tssay llem.alopicttc for Hale A Female 2.7 311.25 2.4 1.0 1.1 7.0 05.3 6.5 4.7 2.0 AM risks are lifetime risks computed as rates per '00,000 of the population at risk. `Risk calculated for Cake Michigan sporlsfir.li eaters who consume an average of l./jig/kg/day PCI1 or 3.0jiy/ki|/day at the 00th percentile. Risks in 'ther areas having similar sportsfisli consumption ami I'lM coniainination are probably similar. A-47 MOWS 0 1 0 0 3 5 .I.. b . .'i.*.-\J***il '' -'*' ^ --r* -i fe W U.tM *'i' Table 7: Upper Confidence Limits (99*) nn Kijubcr of Mei-f Cancers per Year in Caters of Fish Species of Interest Animal Studins on which risks are based - Kimbrough - Rats Liver Carcinoma 50th Percentile Eaters Assuming No Tolerance Take** USA Michigan % Assuming Assuming Assuming Tolerance Tolerance Tolerance = 5 ppm = 2 P|H!I = 1 ppm 90th Porcenti e Eaters Assuming No Tolerance Lake** USA Michiqan Assuming Assuming Assuming Tolerance Tolerance Tolerance 5 ppm = 2 ppm = 1 ppm 6.2 10.<1 5.B 3.8 2.4 16.3 23.4 14.7 10.0 6.7 NCI Bioassay - Total Kalignancies for Male A Female 19.6 32.B 17.6 12.9 7.6 50.6 73.1 46.8 34.3 21 NCI Bioassay - Liver Carcinoma A Adenomas for Male A Female 4.3 7.2 4.2 2.9 2.0 12.0 17.3 10.9 0.0 4.7 NC! Bioassay Hematopoietic (or Mile A Female 12.9 21.6 11.4 8.66 6.3 33.4 46.3 31.0 22.5 13.8 9COOTO SNOW * All risks are the increased number of cancers |Jor year for the population at risk (1S.? of U.S. population) considering a 70 year life span. **l-isk calculated for Lake Michigan r.purtsf isli eaters who consume an average 1.7jnj/kg/day PCfl or 3.9jig/kg/day at the 'JOtii percentile. (4,000,000 people assumed exposed) Risks should be similar lor sportsfish eaters in other areas; bul data, not available to make estimate. -A0 REFERENCES 45-1 Allen, J.R. and Barsotti, Q.A. (1976). The effects of transplacental and mammary movement of PC3s on infant rhesus monkeys. Toxicol. 6:332-340. 43-2 Allen, J.F. and No.-back (1975). Pathobiological response of primates to polychlorinated biphenyl exposure. Proceedincs of the Nation: Conference on Polychlorinated Biohenyls (Nov. 19-21. 1575. Cnicaao. in.) ERA"S5a7T73^rr----------------- -5-3 3chn, A.K., Rcsenweike, I., Hermann, N., Grover, P., Stellnan, J. and . O'Leary, K. (1976). Melanoma after exposure to PCS1s. hew End and # Journal of Medicine 295, 450. *45-4 -ahn, A.K., Grover, P., Rosanwaike, I., O'Leary, K. and Stallman, J. (1977). FC3? and melanoma. Hew England Journal o* Medicine 295, 45-5 Earsotti, C.A., Marlar, R.J., and Allen, J.R. (1975). Reproductive dysfunctions in rhesus monkeys exposed to low levels of poly chlorinated biphenyls (Arochlor 1242). Food and Cosmetics Toxico'ocy 45-5 Caiandra, 2.C. (1ST5). Summary of toxicological studies on commercial PCS's. Proceedincs cf the national Conference on Polychlorinated Biphenyl's (i.ov. 12-21 , 1975, Cnlcago, 111.) EPA-SuO/uI/F-CC-. 35-4-2." 45-7 Ccrdia, F., Corns' iusse.n, ?., Jelinek, C., Keckley, B., Lehman, R., McLaughlin, J. Rhoden, R. and Shopiro, R. (1972). H.-j.n exposure to polychlorinated biphenyls and polybreninated biphenyls. Environmental Health Perspectives 24, 157-172. 45-2 f'.ZV., (1575) final Report cf Suicorsiitiee on Health Effect; s' Polychlororated Biphenyl and Rolybromonated Biphenyls. 45-5 w-.r.phrey, H.E.E. (1975). Evaluation cf changes of the lave' of polychlorinated biphenyls (PC3) in human tissue. Final Resort on FuA Contract 233-73-2209. 45-10 industrial Bio-Test Laboratories, Inc. (1971). Reports to Monsanto Company. Two-year chronic toxicity with Arochlor 1242, 1254, and ' 125' in albino rats. Unpublisned reports, November 12, 1971. ' 1ST Ho. 57293. 45-11 ito, N., Nagasaki, H., Arai, M., Makiura, S., Sugihara, S., and Hiraco, K. (1973). Hisooathologic studies on liver tumoriaenesis induced by nice by technical polychlorinated biphenyls and its promoting effect on liver tumors induced by benetene hexachloride. Journal of the National Cancer Institute 51 , 1537-1546. . A-49 HONS 010037 l i a I [ t i I i &i 45-12 Jelineh, C. and Corneliussen, P.E. (1S76). levels of PCBs in the U.S. food supply. Proceedings of the National Conference on Polychlorinated Biphenyls (Nov. 19-21, 1975). Chicago 111.1 EPA-5o0/,o-/5-0a4> 147-154. 45-13 Johnson, R.D. and Masle, D.D. (1977). Pesticide and Other Chemical Residues in Total Diet Samples (XI). 3esticide Monitoring Journal II, 116-131. "--1 43-K himbrough, R.D., linden, P..E., Burse, V.VI. and Jennings, R.W. (1973). Adencfibrosis in the rate liver, with persistence of poly chlorinated biphenyls in adipose tissue. Archives of Environmental Health 27, 390-395. ----------- ~------- 43-15 Xi-rbrcugh, R.D. and Linder, R.E. (1974). The induction of .idencfibrcsis and hepatomas of the liver in mice of the 3A.L5/C 2 strain by poly chlorinated biphenyls (Aroclor 1254). Journal cf the national Cancer Institute 53, 544-552. 43-15 !'i through, R.D., Squire, R.A., Linder, R.E., Strandbu-c, J.7., Montali, R.J., and nurse, V.V. (1975). Induction cf liver tumors in Sherrran strain facial e rats by polychlorinated i'c'uenyl Ayr cl or 1260. Journal cc she i.'atlcnal Cancer institute 55, 1432-1452. -3-17 Ku.-etsuna, M., Masudo, V. and Nagayama, J. (1975 ). Some of the recent findings concerning Yusho. Proceedings cf the National Conference on PC3s. EPA-56C/5-75-C04, pp. 14-29T "~ -5-13 Kuwabare, K., Yakus.hi j i, T-, Watenabe, I., Yosnida, S., Koy ama, K., Kunita, X., and Hare, I. (1972). Relationship between breast feeding and PCS residues in blood of the children whose mothers were occupationally exposed to ?C3s. Ir.t. Arc'" of Occ-p. Environ. Health 41:133-197, , P..E., Caines, T.5., and Kir.:.-;. gh, R.D. (1974). The effect of po'Olori.mated biphenyls cn rat reproduction. Fend iri Cosmetic Toxicology 12, 3-77). 43-13 'pnsanto (1 375). Industrial Bio-Test . sboratori es, Ire. Resorts. Histopathologioal evaluation additional liver sections. March 24, 1975. Unpublished r'orts, Monsanto Co., St. Louis, Missouri. 43-21 National Marine Fisheries Service (13'5). Compendium cf PCS data. N04A, U.S. Dept, cf Commerce, Washington, O.C. 42-22 National Institute for Occupational Sa-ety and Health (1977). Criteria for a recommended standard..-occupational exposure to poly chlorinated biphenyls (PCEs). :.J (NIJSHi Publication No. 77-225. ' A-50 MOMS 010038 ci -3-2> NCI (National Cancer Institute) (1978). Eioassay of Aroclor 1254 for possible carcinogenicity. Carcinocenesis Teclinical Recor+ Series No. 38. CAS No. 27323-1S-3 NC1-C3-TR-33. (See Ref. 47) ' 4:-24 Najayama, J., Y. Msuda, and M. Kuratsune, (1975). Chlorinated ' Dibenzofurans in Kanechlors and Rice Oils Used by Patients with Yusho, Fukuoka Octa Med, Vol. 56, No. 10, 593-599. 45-25 Spacnoli, J.J. and Skinner, L.C. (1977). PCE's in fish from selected waters of New York State. Pesticide Monitoring Journal 11, 63-87. 45-2: Veith, G.D. (1975). Easeline concentrations of PC3s and DDT in Lake Michigan Fish, 1971. Pest Monitor!no Journal 921-29. 45-27 Walker, C.R. (1975). The occurence of PC3 in the National Fish and Wildlife Monitoring Program. Proceedings of the National Con ference o" Polychlorinated Sfonenv's ;Nov. l3-2l. 19/5. Chicer; in.) EPAooQ/c-?:-^, 161-175.' ' k\ ry 45-25 Zitk Huntzinger, 0 Choi, P.K.K. , Coot ar,'nation of t Bay of Fundy-Gulf f Maine Area with PCSs, PCTs, Chlorinated EB. and BED, Znviron. ealth Persoect. 1:47-50 A-51 MQNS 010039 APPENDIX B PCB Hoc Spot Dredging Program Upper Hudson River, New York, Rescoping Report MPI, February, 1981. Draft PCB Hoc Spoc Dredging Program, Upper Hudson River, New York, Rescoping Reporc. Submitted Co New York Scate Department of Environmental Conservation, Albany, New York. HONS 010040 MALCOLM PIRNIE, INC. Consulting Environmental Engineers WAPORA N. Y. APR 1 1981 4 2 Corporal# Park On mnia Plain# n y 'i0602 S14/094-21OO 11 Computer Or*t W#t. Aifcany NY 12205 11&4S9WM4 002 Canal Road Cuyahoga M*,gni Ohio 4i2S 216/641-5630 Bl6l Busch Blvd . Cotumeua Oh.o 43229 814/M8-49S3 S 35H AbUoti Road. Buffalo nv i4jt9 Ti8-*-'30C O M30M* <H9im<ja>n559n1a Nawoort Nawa. Va 23606 a >00 CiMAftowar On*#, Pvamut. *t j 37652 201/646-040C '617 Jonn F Nannaoy BN4. 215/564-0173 artamna B i#io# 6757 OaorgM Aw#. 5^war Soring. M# 3Q91Q 301.587-5355 300 Soutn 22 SI iSun# 2<2) 9irwiwan#m. At# J0233 205/332-061} 2500 Hollywood 0ivd Hollywood fla 33030 305 923-813' To: _I Atlenlion: IQQL7- Dale: MdrcL 31, l^Rf__________________ Re Itvtr PCA ------PenjYcf_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ------- 'Ejnp'4 GENTLEMEN: Ex **33 We are sending you B Enclosed Under separate cover via B Mail Messenger, the following items shop drawings prints data sheets B ~%epcri specifications sketches brochures Our action relative to items submitted lor approval has been noted on the drawings. COPIES 1 1----------- PREPAREO 8Y REFERENCE NO mn ______ DESCRIPTION -T'HAl Dosrr of -we ^oaPi N6 ZzpoCX XutrtO MAtPM, l9fl In- * I_____ U THESE ARE TRANSMITTED AS CHECKED BELOW As requested 8 For your use For review & comment For your information Approved Approved as Corrected Q Revise and Resubmit Not Approved Q Resubmit_____copies for approval Submit_____copies for distribution _O Returncorrected Prints Remarks: _S__Ac Axx/M&hJLl 1A. Atfa., --<out*JuL ttmIsJtM. *7Tree iu*t het.--*+ jutti. iVa.4- ft Oj Fh^u*. } a* ^ jt an h hi juJ,l___________________________________________________________________________________ - --. - x*~ 7 Copies to: ffThe\vs Very truly yours MALCpJLM PIRNIE. INC. by HONS 0X0041 HUDSON RIVER PCB RECLAMATION PROJECT SCOPING REPORT MARCH 1981 BACKGROUND This rescoping of the PCB hot spot dredging project has been prompted by the limited funding available to undertake the work. The cost of the original 40 hot spot dredging program, including construction of the containment site and removal of remnant deposit areas 3 and 5 (remains of the former Fort Edward Pool deposits above Fort Edward) was an estimated $40 million. Total funds available for the project at this time are $26.7 million, and the purpose of this review is to identify the most beneficial and cost-effective combin ation of project elements which can be completed for this amount. This report briefly describes the original hot spot dredging program as evaluated in the Draft Environmental Impact Statement, New York State Environmental Quality Review (Draft EIS, New York SEQR), as well as associated actions which include relocation and containment of contaminated New York State Department of Transportation (DOT) dredge spoil material and nearby dumps. It then presents a discussion of discrete elements of the $40 million project, criteria for a rescoped project, a proposed reduced scale program. BRIEF DESCRIPTION OF ORIGINAL PROJECT The original project, as presented in the Draft EIS, included six components directed toward reducing the impact of PCB on the Hudson River, its biota, and the surrounding Hudson River Valley. These components we.-;: 3-2 HONS 010042 o Dredging of 40 hot spot^1^ areas in the river bed with containment in a secure upland site. o Design and construction of a secure upland contain ment site capable of long-term isolation of contami nated material. o Excavation of remnant deposit areas 3 and 5, located above the former Fort Edward Dam site, and removal to the upland containment site. o Provision for containment of material from three PCB-contaminated dump sites in the Fort Edward area - Old Fort Edward, Fort Miller and Caputo should removal be found more suitable than in-place containment. o Provision for containment of contaminated material from three DOT dredge spoil areas - Spoil Area 13, site 212 and Site 204 Annex. o Destruction of the recovered PCB at such time as a technically and economically feasible procedure becomes available. If relocation of the above mentioned dump and spoil area material were to take place in conjunction with the dredging of all 40 hot spots and the removal of remnant deposit areas 3 and 5, almost half of the PCB estimated to be in the Hudson River and adjacent land areas would be permanently contained. (See Table 5.; However, this figure includes the movement of DOT spoil areas and highly concentrated dump materials, and therefore does not represent the reduction of PCB in the river itself. Dredging of the 40 hot spots and excavation and movement of all of remnant deposit areas 3 and 5, would result in a 54 percent reduction in the mass of PCB contained in the bed and banks of the Upper Hudson. The bed and banks of the Hudson River, as defined here, include all of the hot and cold areas in the Upper Hudson River (bed) and the remnant deposits [1] Hot spots have been defined as areas of PCB contamination equal to or greater than 50 |jg per g. HONS 010043 B-3 (banks). Dredging all of the 40 hot spots would alone result in a 49 percent reduction in the mass of PCB in the bed of the Upper Hudson River and a 33-35 percent reduction in the mass of PCB in the bed and banks of the Upper Hudson River. A reduction in the scope of this project would result in a corresponding reduction in the amount of PCB removed from the river. This relationship is not linear, and the revised project will be designed to recover the greatest mass of PCB potentially subject to loss to the water column for the funds available. Table 1 presents an estimate of the cost of the original 40 hot spot project. The $40 million cost indicated was based on construction of the containment site in 1981, and a two year dredging program in 1982 and 1983. ORIGINAL PROJECT General The proposed program was to have a three year duration. The first year included site construction and probing and sampling of lower pools. The second year included dredging the 20 hot spots in the Thompson Island pool, removal by truck, partially or completely, of the Area 3 -nd 5 remnant deposits, and subsequent covering of the required portion of the containment area. In the third year, the lower pools were to be dredged, and the remainder of the containment area covered and sealed. In addition, the nonpermanent earthen basins on the site were to be razed and these areas regraded. In this section each element of the program will be described. The cost associated with each is presented in Table 1. A location map is presented in Plates 1 and 2. Data Used The quantities of contaminated volumes to be removed and associated PCB masses for each of the hot spots are those computed by Malcolm Pirnie, Inc. (MPI 1978). HONS 010044 B-4 TABLE 1 ESTIMATED COSTS FOR ORIGINAL 40 HOT SPOT DREDGING PROGRAM (All costs in thousand dollars) Phase Site Construction^ 1981 $4770 Cover costs Site Modifications After Closure Thompson Island.. Pool Dredging' Remnant Deposits Removal Lower Pool Hot Spots Dredging Lock 6 Lock 5 Lock 4 Lock 3 Lock 2 - Material Rehandling Sub-Total $4770 Contingencies 480 Engineering Design 278 Field Engineering & Construction Atainistration 384 Legal & Actainistrative 69 Totals By Year $5981 1982<4) $ 789 6534 1670 1983^4) $ 868 429 Total bv Phase $ 4770 1657 429 6534 1670 221 $9214 2525 930 1062 257 $13,988 844 2826 1329 1371 1457 199 $9323 2624 1018 1493 293 $14,751 844 2826 1329 1371 1457 420 $23,307 5629 2226 2939 619 $34,720 Three Year Total $34,720 Scientific, Engineering, Monitoring 6 Atainistrative Costs 9/76-3/80 3,480 Scientific, Monitoring & Administrative Estimated 4/80-3/83 1,800 Project Total $40,000 Notes: (1) Includes site work costs for all phases, except site modifications after closure and cover costs. (2) Includes south dike channel, additional swale drops, and razing and regrading the roughing & storage pond, surge pond and the treatment plant basins. (3) Escalated 13.2 percent from third quarter 1980 to mid-1981. (4) Escalated 24 percent from 1979 to 1980, and 10 percent/year from 1980. (5) Includes site acquisition costs. MONS 010045 Related Studies More detailed descriptions of each of the project elements and their costs can be found in the following previous reports: o Phase I Engineering Report, Dredging of PCB Contam inated Hot Spots, Upper Hudson River, NY. Malcolm Pirnie, Inc. (December -------------- ------- o Design Report, PCB Hot Spot Dredging Program Contain ment Site, Malcolm Pirnie. Inc. (September 1980). o Dredging System Report. Program Report No. 2, PCB Hot Spot Dredging Program, upper Hudson River, nY. Malcolm Pirnie, Inc. (September 1980). o Draft Environmental Impa"1- ------ ----------- --- - - t Dredging ProgrLaamin,, Uupp:uei Pirnie, Inc. (September 1980). Containment Site The containment site, referred to as Site 10 in earlier reports, is situated on a 250 acre parcel of land located approximately 2.5 miles south of the Village of Fort Edward, in the Town of Fort Edward, in Washington County, New York. (See piate 3). The site's major components are: o Containment .\rea o Roughing and Storage Pond o Surge Pond o Water Treatment Plant o Pump station o Leachate Collection System o Access Road o Storm Water Drainage System o Chemical Feed System o Appurtenances Containment Area - The containment area is an earthen basin bisected by a cross dike. It occupies approximately 63 acres at its maximum water surface and its total containment HONS 010046 B-6 volume at the maximum water surface is 2,260,000 cu yds. This volume is sufficient to hold all of the 40 hot spots, remnant deposit areas 3 and 5 and the DOT spoil areas. The containment area is designed for long term encapsula tion of PCB-contaminated materials, and will therefore be capped with a clay cover during each season of dredging. Roughing and Storage Pond - The roughing and storage pond (R&SP) is an earthen basin with a maximum water surface area of approximately 12 acres. After the slurried dredge material is pumped into the containment area, weir overflow is transported via pipeline to the R&SP. The primary purpose of this basin is to ensure efficient sedimentation near the end of each dredging season as the effective overflow rate in the containment area de creases. The R&SP also provides protection for the subsequent treatment units from any upsets in the containment area which might lead to transient escape of dredged material. A small portable dredge will be operated to recycle settled dredged material bach into the containment area. The R&SP is not a permanent containment unit. At the end of the dredging program, all of the contaminated material in the R&SP will be relocated to the containment area and the pond will be filled in and regraded. Surge Pond - The surge pond is an earthen basin with a maximum water surface area of 2.4 acres. This pond receives weir overflow from the R&SP. Its purpose is to buffer the treatment plant units from surges in the dredging process and to provide a convenient, sediment-free point for treatment feed and recycle supply pump suctions if a recycle dredging procedure is implemented. A detailed discussion of dredging options is presented in the Containment Site Design Report. Water Treatment riant - The water treatment plant consists of two earthen basins, the flocculation basin and the settling basin, with maximum water surface areas of 0.1 and 1.0 acres. HONS 010047 B-7 respectively. The plant has a capacity of 13 million gallons per day (mgd) and consists of coagulation, flocculation and sedimentation units. The purpose of the water treatment plant is to reduce PCB concentration in the dredge return flow before discharge to the river. The water treatment plant is expected to achieve effluent suspended solids less than 4 milligrams per liter and turbidity less than 10 NTU with proper chemical doses. The average PCB concentration in the discharge is expected to be in the 10-20 microgram per liter range. Pump Station - The pump station consists of three mixedflow pumps each with a capacity of 4500 gallons per minute (gpm). One of the three pumps functions as a standby. The pump station's function is to provide a reasonably constant influent feed to the water treatment plant. Leachate Collection System - The leachate collection system is a network of perforated drainage piping laid in gravel-filled, filter-cloth-lined collection trenches at the base of the containment area. The bottom of the containment area is sloped to transmit flow towards the trenches. The leachate collection system will be utilized in two phases: short-term dewatering and long-term percolation. A piping system connects the drainage system to a dis charge point at the Hudson River. Valves, collection and sampling wells, and a flow meter ing and monitoring manhole are provided to determine the quantity and concentration of ?CB in the leachate. Discharge to the Hudson River will only be permitted if the observed leachate quantities and concentrations will have no adverse impact on the River. If river discharge proves unacceptable, the leachate will be stored in-place and periodically collected and treated. Stormwater Drainage System - The stormwater drainage system will intercept and convey stormwater runoff that would HONS 010048 B-8 have directly affected the containment site. Precipitation falling on the containment site, and on the watershed north of the containment site, will be transported by the drainage system to the Hudson River. The components of the drainage system include a combina tion of swales, open channels, and closed conduits. Access Road - An access road will be provided between Route 4 and the chemical feed building. This roadway will permit access to tank trucks delivering bulk chemicals, as well as access and parking for contractor, engineer and DEC personnel. Chemical Feed System - The pumps, piping, tanks and dilution water needed for the chemical feed system for the treatment of the dredged slurry will be housed in a chemical feed building. Appurtenances - Also including in the construction site requirements are electrical services, fencing, seeding, clear ing and grubbing of wooded areas and monitoring wells. Thompson Island Pool The Thompson Island Pool is located between the Thompson Island Dam and Rogers Island. Th" areas to be dredged are the 20 identified hot spots (including four above Lock 7) with a volume of approximately 645,500 cu yds and 105,800 lbs of PCB (see Table 2). ' Under the original program, the Thompson Island Pool hot spots were to be dredged in the first dredging season. Lower Pools Under the original program, the second season was to consist of dredging the five lower pools: o Lock 6 pool o Lock 5 pool o Lock 4 pool MONS 010049 B-9 TABLE 2 REMOVAL VOLUMES AND MASS OF PCB PROPOSED FOR MOVEMENT TO CONTAINMENT SITE UNDER THE ORIGINAL PROGRAM Hot Spot Number 1-4 5-20 Location Above Lock 7 Thompson Island Pool Volume to be Removed , > (cubic yards)'1' 22,800 622,700 PCB Mass (pounds) 900 104,900 PCB Concentration in Dredged Material (UQ/d) 24 96 21-27 Lock 6 Pool 68,900 28-35 Lock 5 Pool 296,700 36 Lock 4 Pool 134,200 37 Lock 3 Pool 137,800 38-40 Total Lock 2 Pool 149,600 1,452,700 Remnant Deposits (maximum removal volumes) 4,900 31 33,700 65 5,000 21 11,700 48 8,800,.. 12(1) 169,900U; average*67x ' Area 3 Area 5 Total Dump* (Non-secure Landfills) 160,900 51.600 212,500 18,500 66 22,700 250 41,200 average* 110 Old Fort Edward Fort Miller Caputo DOT Spoil Areas 1,000 7,400 200 8,600 208,000 119,000 1,130-10.000 328,100-337,000 Spoil Area 13 Site 212 Site 204 Annex Total 191,000 77,000 3.000 271,000 1,944,800 25,000 10,000 300-700 35,300-35,700 574,500-583,800 (1) The dredged materiel volume and concentrations are calculated using a 36 inch removal depth which includes an overcut of essentially uncontaminated material. Contrac*"l incentives to limit depth of cut to 24 inches could reduce removal volumes and increase concentrations. (2) The total mass of PCB in the bed of the Upper Hudson River is estimated to be 347,200 lb. The remaining 177,300 lbs of PCB are present in "cold areas" with PCB concentrations less than 50 pg/g. Sources: Weston (1978) MPI (1978) DEC (March 1980) Estimates rounded to nearest 100 cubic yards or pounds B-10 MONS 010050 o Lock 3 pool o Lock 2 pool The removal volumes and associated masses of PCB for each of these pools is listed in Table 2. Remnant Deposits The remnant deposits are PCB-contaminated areas adjacent to the Hudson River upstream of the former Fort Edward Dam. These areas are the remains of 150 years of deposition behind the dam, exposed as dry land following dam removal in 1973. Much of the deposited material has washed downstream; those areas which remain have been designated remnant deposits. Under the original project remnant deposit areas 3 and 5 were to be partially or completely removed and placed in the containment site during the first season of dredging. Area 3 has a complete removal volume of 160,900 cu yds containing an estimated 18,500 lbs PCB. Area 5 has a complete removal volume of 51,600 cu yds containing an estimated 22,700 lbs of PCB. DOT Spoil Areas Threv. DOT spoil sites, containing a total of 271,000 cu yds of material and approximately 35,000 lbs PCB (average concentration 50-100 pg per g) were proposed for movement to the containment site under the original program. This is material that has already been removed from the river, top dressed and seeded. The containment site was designed to have capacity for this material, though its movement was neither evaluated in the draft EIS, nor considered to be a part of the hot spot dredging program. Dump Sites Seven dumps in the Fort Edward area contain capacitor wastes and other concentrated PCB materials. Under the origi- B-ll HONS 010051 nal program, an area was to be provided for the contents of the Old Fort Edward, Fort Miller and Caputo dumps (total 8,600 cu yds; 328,100 - 337,000 lbs PCB) in a segregated cell at the containment site. Movement of the dumps was not a component of the hot spot dredging program, was not evaluated in the draft EIS, and wa6 not included in the cost estimates for the hot spot dredging project. CRITERIA FOR RESCOPING General A preliminary review of the cost summary for the original 40 hot spot project shows that in order to meet the budget constraints major elements of the project will have to be deleted. Therefore, a set of criteria for inclusion in the rescoped project were defined. The major criteria discussed in this section are: o Maximization of PCB removal from the Hudson River o Program Performance o Cost-Effectiveness o Wetlands Avoidance o Flexibility Maximization of PCB Removal from the Hudson River The main objective of the project is tc stabilize the maximum amount of PCB-contaminated material thereby minimizing its uncontrolled migration. Because the remnant deposits, DOT spoil areas and dumps are more stabilized than the in-river PCB-contaminated material, this objective will be best realized by maximizing the PCB removal from the hot spots in the Hudson River. Program terformance The rescoped project maintains the same level of control on performance of the dredging and return flow treatment 3-12 HONS 010052 systems, and containment site design criteria as was incorpo rated in the original hot spot dredging program. Cost reduc tions have been achieved through elimination of specific project elements. The quality of design and operational controls has not been relaxed. Cost-Effectiveness The priority of pools for dredging has been evaluated by developing an associated cost per pound of PCB removed per pool for the dredging, transport and treatment required. Pools are prioritized for removal beginning with those which have the lowest unit cost for PCB removal and containment. This results in concentrating dredging efforts on the most readily accessible and most highly contaminated pools. Wetlands Avoidance PCB which is contained in wetland sediments is, in effect, stabilized in place by root systems, and is, therefore, less subject to flood scour losses, though ice scour may result in some erosion of contaminated material. Wetlands in the river did not experience significant erosion during the 100-year flood in 1973. Some sediment PCB may be dislodged or taken up by burrowing organisms, but this mechanism occurs throughout the Upper Hudson. Recent sampling of hot spot 28, the most highly contaminated wetland in the river, found above-ground leaves and stems of wetland plants to average 1-4 parts per million PCB (Buckley 1981). Though contaminated to some degree, wetlands in the river offer cover, brooding areas, and food for a variety of resident and migratory wildlife species. Biologists from DEC, MFI and the Boyce Thompson Institute have noted the biological value of these wetlands, and recommended that they not be removed. Dredging efforts '.rill be concen trated on the less stable, and less biologically productive hot spots. Using this criteria, hot spots 25, 28, 35 and 40 3-13 HONS 010053 have been identified as containing significant wetlands and hence have been given a low priority for removal. THE RESCOPED PROJECT General Using the above stated criteria the following modifica tions were made to the original project. o Deletion of remnant deposit relocation. o Provision of top dressing and fencing for remnant deposit Areas 3 and 5. o Elimination of provision for the containment of PCB contaminated dumps. o Reduction of number of hot spots to be dredged. o Reduction of capacity at the containment site, resulting from the above reductions in volumes of material to be encapsulated, as well as a better definition of materials handling requirements at the site. o Reduction in the scope of research studies. This section will discuss these modifications, and detail the elements of the rescoped project. Remnant Deposits Until it is demonstrated that the remnant deposits are indeed leaching PCB, these deposits will be considered more stable than the hot spots. No remnant deposit removal is recommended at this time. Top dressing and fencing of Areas 3 and 5 has been sug gested as a means to minimize volatilization and public access. It should be noted that a proposal to reconstruct the Fort Edward Dam is under consideration. Reestablishment of the Fort Edward Pool may affect the stability of the remnant deposits requiring consideration of capping or other measures at that time. B-14 HONS 010054 DOT Spoil Areas The USEPA (1981) has advised that not all of the DOT spoil areas have been covered properly in accordance with the Toxic Substances control Act. Although funding is not included in this program for the removal and transport of these areas to the containment site, the containment area has been designed under the rescoping project with an excess capacity that could be used to accommodate the DOT spoil areas. Dump Sites Under the September 23, 1980 agreement between DEC and the General Electric Co., responsibility has been delegated to General Electric and others for the remediation and long-term maintenance of these dumps. Therefore, all provisions for these dumps have been eliminated under the rescoped project. Hot Spot Dredging The reduced budget for the hot spot dredging program introduces increased importance to the selection of a dredging system for the Thompson Island Pool. The original program defers final selection of either a hydraulic or clamshell/ pump-out system until the competitive bidding for the dredging. At that time the cost-performance characteristics of the systems could be based upon conclusive cost data. With a reduced scope program significantly less funds will be available for the second season dredging of the lower pools. If a clamshell/pumpout system is not used at Thompson Island pool remaining funds may not allow construction and amortization of special equipment that would be required for the lower pools. The impacts of this situation should be evaluated in detail in the upcoming pre-design studies for Thompson Island Poo1 Results of these studies may indicate that hydraulic dredging of Thompson Island is not feasible in the total rescoped program. B-15 MONS 010055 Although not evaluated in this report, the reduced hot spot dredging will tend to reduce contaminant mass emission rates resulting from project operations during the life of the program. Thompson Island Pool - The Thompson Island pool is a clear choice for inclusion in the rescoped program. Cost analysis indicates that the dredging, transport and treatment cost per pound of PCB removed in this pool is $62. This is the lowest unit cost for any of the pools. In addition, probing and sampling programs have been more detailed in this pool than in any other, permitting confidence in the PCB location and concentration data used. Studies have also shown that the river bed materials in this pool are subject to scour, and that there is no significant conflict with wetlands in the hot spots in this pool. Finally, this pool is located closest to the containment site, facilitating transport. Lower Pools - Based on a range of costs per cubic yard for dredging, transport and treatment, between 160,000 and 265,000 cu yds of material could be dredged in the lower pools within the budget constraints of the rescoped project. Using the MPI estimates of contaminated volumes and PCB masses listed in Table 2, and applying the criteria discussed previously to each of the lower pools, results in the prior itization of hot spot dredging by pool as shown in Table 3. Incorporating the range of lower pool dredging - 160,000 to 265,000 cy yds - with the volumes listed in Table 3 yields the following. Using the lower range value of 160,000 cu yds only hot spots 29-34 in the Lock 5 Pool will be dredged. Using the higher range value of 265,000 cu yds, both hot spots 29-34 in the Lock 5 Pool and approximately 80 percent of hot spot 37 in the Lock 3 Pool will be dredged. Table 4 details the hot spots to be dredged under the rescoped program. B-16 HONS 010056 I I TABLE 3 PRIORITIZATION OF HOT SPOT DREDGING BY POOL Priority Number 1 2 3 4 5 Location Lock 5 Pool Hot Spots to be Dredaed 29-34*11 Volume to be Removed (cu yds) 155,350 Lock 3 Pool Lock 2 Pool 37 3S-39*2* 137,800 67,000 Lock 4 Pool Lock 6 Pool*4> 36 21-24 and(3) 26-27 134,150 55,500 PCB Mass (lb) 22,530 11,680 5,020 5,000 2,460 Cost per lb PCB Dredged, Transported and Treated (1983 dollars) $100-170 $180-290 $200-330 $400-670 S340-560*4* (1) Hot Spots 28 and 35 have been identified as containing significant wetlands and hence have a lower priority for resioval. (2) Hot Spot 40 has been identified as containing a significant wetland and hence has a lower priority for removal. (3) Hot Spot 25 has been identified as a significant wetland and hence has a lower priority for removal. (4) Lock 6 Pool is non-navigable and therefore inaccessible to dredging without special provisions incurring considerable expense, cost per lb PCB removed does not reflect these additional costs. Note: Prioritization was done using the MPI estimates of contaminated volumes and PCB masses listed in Table 2. B-17 HONS 010057 Pool Thompson Island Lock Pool Thompson Island Lock 5(1> Lock 3<2> TABLE 4 RESCOPED PROGRAM Hot Spot Dredging High Estimate of Unit Cost Hot Spots 1 thru 20 29 thru 34 Contaminated Material vol, cu vd PCB Mass, lb 645,500 105.800 155,350 22,530 800,850 128,330 Hot Spot Dredging Low Estimate of Unit Cost Hot Spots 1 thru 20 29 thru 34 37 partial Contaminated Material vol, cu vd PCB Mass, lb 645,500 105,800 155,350 22,530 109,6S0 9,310 910,500 137,640 (1) Hot Spots 28 and 35 are identified as containing significant wetlands and hence have a lower priority for removal. (2) Partial removal will recover approximately 80 percent of in-place PCS in Hot Spot 37. Note: All values based upon MPI estimates as presented in Draft EIS, N.7. State Environmental Quality Review, September 1980. B-18 MONS 010058 Under the rescoped dredging program between 37 and 40 percent of the 347,200 pounds of PCB in the hot and cold spot in the Upper Hudson river bed will be dredged. Under the original project, 49 percent of the PCB in the river bed was expected to be dredged. The PCB masses used in calculating these percentages are the total masses of PCB associated with the volumes of material expected to be dredged. These percent ages therefore do not reflect quantities of PCB missed in the dredging process, lost to the water column or returned to the river in treatment plant effluent. Earlier studies have shown that the losses in these three areas total in the range of 6 to 9 percent. A comparison of the percentage removal of PCB under the original and rescoped project is shown in Table 5. Estimated costs for the rescoped program are presented in Table 6. This dredging program is based upon removal of hot spots as complete units with partial removal when estimated project funds will not allow for complete removal of the last hot spot dredged. Those hot spots which contain wetland areas have been avoided. An alternative removal program would be to make partial removal of a hot spot area on the border of a wetland and leave the wetland area undisturbed. The additional probing and sampling program proposed in 1981 will provide the detailed data necessary for developing such a removal program. Some existing additional data not used in the present analysis will also assist in such an effort. An alternative program involving partial removal of hot spots containing wetlands may give a slightly higher removal of PCB than the rescoped program described herein. The dif ferences, however, will not significantly change the environ mental and cost impacts of alternative removal programs. B--19 HONS 010059 TABLE 5 PCB QUANTITIES TO BE CONTAINED UNDER THE ORIGINAL AND RESCOPED PROJECT Location Upper Hudson River Bed Hot Spots Cold Areas Subtotal Remnant Deposits (Banks) Subtotal DOT Spoil Areas^ -Dumps <*) Hass of PCB (lb) 169,900 177,300 347.200 46,770 393,970 71.4SS-96.980 736,130-745,000 Oriainal Project Hass of PCB to be % Removal Removed from of PCB frym Location (lb) Location' 1 169,900 0 169,900 4l,200<2) 100% 0% 49% 88% 211,100 54% 35,300-35,700 ^ 37-49% 328,100-337,000<5)1 44-45% Totals 1.,201,555-1,235,950 574,500-583,800 47-48% Rescoped Project Hass of PCB to be % Removal Removed from of PCB frji Location (lb) Location' 128,330-137,640 0 128,330-137,640 0 128,330-137,640 35,300-35,700(4) 0<6> 163,630-173,340 76-81% 0% 37-40% 0 33-35% 37-49% 0% HONS 0 1 0 0 6 0 (1) Removal estimates do not account for quantity of PCB missed in the dredging process, to the water column during dredging, or returned to the river in treatment plant effluent. (2) Remnant deposit areas 3 and S - complete removal. Partial removal options not included. (3) Materials which are not planned for movement under rescoped project, but for which containment site capacity exists. (4) Three DOT spoil areas - Spoil Area 13, Site 212 and Site 204 Annex. (5) Three dtaaps - Old Fort Edward, Fort Hiller and Caputo. See (6). (6) All dumps to be stabilized in place under the DEC - General Electric agreement of Septemter 23, 1980. B-20 TABLE 6 ESTIMATED COSTS FOR RESCOFED PROGRAM (All costs in Thousand Dollars) Phase Site Construction^ and Acquisition Intermediate Cover Cover Costs I981(3) 1982^4) $3905 $ 100 Site Modifications After Closure' Remnant Deposit Areas 3 & 5 Top Dressing and Fencing 200 Thompson Island Pool Dredging Lower Pool Hot Spots Dredging 6534 Material Rehandling Sub-Total $4105 221 $6855 Contingencies Engineering Design Probing and Sampling Monitoring Field Engineering & Conatruction Adainistration Legal & Administrative Totals By Year Total For Project 371 978 500 &00 384 290 $7228 2057 800 100 400 880 305 $11,397 $1071 429 3060 199 $4759 1428 50 400 1078 320 $8035 'll Total bv Phase $ 3905 100 1071 429 200 6534 3060 420 $15,719 3856 1828 600 1400 2342 915 $26,660 $26,660 Notes: (1) Includes site work costs for all phases, except site modifications after closure and cover costs. (2) Includes south dike channel, additional swale drops, and razing and regrading the roughing & storage pond, surge pond and the treatment plant basins. (3) Escalated 13.2 percent from third quarter 1980 to mid-1981. (4) Escalated 24 percent from 1979 to 1980, and 10 percent/year from 1980. 3-21 HONS 010061 Containment Site The original containment area had an approximate capacity of 2,260,000 cu yds. This provided for all 40 hot spots, remnant deposit areas 3 and 5, and the three selected DOT spoil areas. Under the rescoped project, the required con tainment volume was reduced due to the deletion of remnant deposit relocation and containment and the reduction in hot spot dredging. In addition, the fluff factorapplied to the dredged hot spot material in the Thompson Island pool was reduced due to a probing and sampling program done in this pool, autumn, 1980, by Gahagan, Bryant & Associates. For these reasons, the required containment capacity under the rescoped project is approximately 1,100,000 cu yds. This capacity is sufficient to accommodate hot spots 1 thru 20 in the Thompson Island pool, hot spots 29 thru 34 in the Lock 5 pool and hot spot 37 in the Lock 3 pool, all with the required fluff factors. The actual capacity of the rescoped containment area was determined by reducing the size of the original containment area to a point where further reductions resulted in only minimal savings. The capacity of the rescoped containment area is approximately 1,400,000 cu yds. This additional volume of 300,000 cu yds gives the project the flexibility to accommodate any of the following: o Containment of DOT Spoil Areas - Spoil Area 13, Site 212 and Site 204 Annex o Partial Remnant Deposit Removal and Containment Partial Area 3 and Complete Area 5. o Complete remnant deposit removal - Areas 3 and S. o Containment of any additionally dredged hot spot materials if costs are less than expected or more monies become available. [1] huff factor is defined as the ratio of volume in containment to volume in situ. B-22 HOMS 010062 o Provision for the occurrence of unexpectedly high fluff factors. The funding for any removal and transport of either the DOT spoil areas and the Remnant Deposits is not included under the rescoped project. On the basis of the rescoped containment areas reduced volume the following modifications were made to the contain ment site: o Reduction of leachate collection system o Revised and reduced storm water drainage system o Reduction of appurtenances These reductions in the containment site result in a cost savings of $1,065,000. The proposed two season dredging plan will still be incorporated in the rescoped project. The contaminated mate rial dredged during the first season will be covered between the two seasons. The Thompson Island dredged material will be placed in one half of the containment area, and capped with a permanent clay cover. The final clay cap cover has also been reduced by the rescoped containment area. Other areas of possible savings which will be investi gated in the redesign are: o balancing cut and fill operations o lowering containment dike heights o using filter fabric and additional crushed stone in lieu of paving storm water drainage channels o leaving the roughing and storage, surge pond, and treatment pond dikes in place after completion of dredging program B-23 HONS 010063 OTHER PROGRAM ELEMENTS Probing and Sampling Program Prior to dredging any of the pools below Thompson Island, there will be a comprehensive program of probing for bottom characteristics and sampling for PCB contamination in these down pools. This additional data is essential to more pre cisely delineate hot spots and will be used to finalize the lower pool dredging strategy. Sediment samples will also be taken at remnant deposit areas 3 and S to verify depth of contamination. In addition, additional sampling will be done in the Hudson River above and adjacent to these deposits to determine their PCB contribution to the water column. The lower pools dredging program and any actions taken at the remnant deposits will reflect the results of these studies. Monitoring Program A brief description of the proposed program for monitoring the effectiveness of the dredging program follows. A more detailed description is under preparation by DEC and will be available by mid-March. The program will include two overlap ping categories of monitoring, environmental and operations. Environmental monitoring will involve atmospheric, aquatic and terrestrial sampling before, during and after the comple tion of dredging activities. Samples will be taken at least daily during dredging and more intensively during early phases of the project to provide supplemental operations control data. Dredged material will be regularly sampled to assure that the dredging operation is recovering contaminated material. Environmental monitoring after the completion of dredging will record the more immediate effects of the PCB dredging program on PCB levels in the air and water; and, later, any residues on land, foliage and in animal tissues. 3-24 MONS 010064 The following studies will be included under the environ mental monitoring program: o Sediment Transport Monitoring o Hudson River Fish Flesh PCB Analysis o Sediment PCB Desorption Study o Biological (Macroinvertebrate) PCB Uptake Study o Foliar Contamination by PCB in Washington County Forage Crops o Air-Plant PCB Relationships o Agricultural Inplace Studies, o Site 10, ground water monitoring. Operations control includes both monitoring and dredge control. The dredge phase losses, bucket losses, losses to the water column and air, and the loss of PCB in the treatment plant effluent will all be monitored. The purpose of the monitoring is not simply to record the effectiveness of the related processes, but to provide "real time" data that can increase and maintain the best attainable dredging efficiency. RESCOPED PROGRAM SCHEDULE In this section the assumed schedule for the rescoped project is presented: o Containment Site Construction (Summer 1981) o Sampling and Probing Program (Summer 1981) for the Lower Pools o Dredging Thompson Island Fool (Summer 1982) o Additional Sampling and Probing Program for the Lower Pools, if Required (Summer 1982) o Partial Closure of Containment Area (1982) o Dredging of some of the Lower Pools (Summer 1983) o Final Site closure and Site Modifications after Closure (1983) o Monitoring before, during and after all phases. B-25 HONS 010065 REFERENCES 1. Phase 1 Engineering Report, Dredging of PCB Contaminated Hot Spots, Upper Hudson River, NY. Malcolm Pirnie. Inc., (December 1978). 2. PCB in Sediments and Water, and Their Transport. New York State Department of Environmental Conservation, (March 1980). 3. Telephone conversation between Dr. E.H. Buckley, Boyce Thompson Institute, and James Catterton, MPI, (January 30, 1981). 4. Comments on PCB Hot Spot Dredging Program, Upper Hudson River, New York, Rescopinq Report, USEPA, (February 1461). B-26' HONS 010066 APPENDIX C Review of Che Sediment Transport Model and Che PCB Ecosystem Model Appendix C contains a review by WAPORA, Inc. of Che Sediment Transport Model (Lawler, Matueky and Skelly Engineers, 1978; 1979) and the PCB Ecosystem Model (Hydroscience, Inc., 1978; 1979). MQNS 010067 Appendix C ]. REVIEW OF LMS SEDIMENT AND TRANSPORT MODEL A sediment end PCB transport model was developed by Lawler, Matusky A Skelly Engineers to assess the impact of the "No Action" alternative and subse quently to evaluate two "Action" alternative schemes. The results of these modeling studies are presented in two reports by Lawler, Matusky & Skelly Engi neers (LMS 1978, 1979). This review is designed to put the PCB transport in the Hudson River into perspective with the "No Action" alternative. The review is concentrated in two aspects: overall methodology and technical results. The overall methodology adopted by Lawler, Matusky & Skelly Engineers is not clearly understood. This selection of the HEC-6 model as the basis of the sediment transport model seems adequate but without a thorough discussion of the other models available. A model review and selection process is missing from the report. Further, the linkage of the HEC-6 model and the water quality problem (in this case, PCB transport in the Hudson River) is lacking. This stay be due to the lack of discussion of the goals of this modeling study. In addition, how the temporal and spatial scales of the selected model and of the water quality parameters to be addressed match is not presented. The biggest drawback of the LMS approach of using the HEC-6 model is that the HEC-6 model is designed for alluvial scream beds while the PCBs in the Hudson River are associated with fine organic materials. The sedimentation characteristics between alluvial channels and fine-particle beds are quite different. After all, the PCBs in the hot spots are primarily associated with the fine organic particles (Heeling et al. 1978). It should be pointed out that the LMS sediment and PCB transport model have been calibrated but not verified because of lack of adequate data. The most difficulty encountered in reviewing the LMS report is Chapter 4, Model Calibration. There are significant amounts of data analysis presented in this chapter such that it ia difficult to differentiste which is data analysis C-l MQNS 010068 and which is model calibration. Further, in moat casea, the data are ao scat' tered and not substantial. The comparison of model calculation with observation seems more like a pure model calculation. Usually, at the end of model cali bration, a summary of key model parameters is presented. This particular list is missing which makes Che review extremely difficult. At best, only the model segmentation list is found in Appendix D without any ocher parameters (such as hydrographic characteristics, at the least) used in model calibration. It is understood that the HEC-6 model calibration was based on a relatively short time period of field survey data. In order to conduct long-term projec tions of PCB movement, a proper transition from short-term computation and long-term projection is required to accommodate such a change in temporal scales. The reportstops short of its transition effort at statistical analyses of the Hudson River and tributary flows. The other key features of the sediment and PBC transport such as upseream boundary conditions are not specified. Subsequently, a summary of the model projection scenarios is not presented, although model projection runs were conducted for constant source, diminishing source, snd flow control conditions. Based on the above discussion, the LMS modeling is not considered e atsCe-* of-the-art approach. Additional data are required to further refine the calcu lations. Therefore, the results from the LMS study should not be taken as the definitive predictions of PCB transport in the Hudson River. Instead, the results can be considered as the "best" estimate and trends of PCB loadings from the upper Hudson River to the estuary. Effort should be examined to construct a rational and credible analysis of the transport and ultimate fate of PCBs in the movable bed sediment PCBs, the PCBs in the sediments, and the PCBs in the water column, in order to estimate accurate transport loads in the Hudson River. Nevertheless, the LMS studies provide as preliminary assessment of average annual PCB loads to the estuary in terms of No-Action, Remnant Deposits Mitiga tion, and Hot Spot Dredging alternatives. The results of the LMS studies have been modified by WAPORA in order to reflect the effects of volatilization and routine navigational dredging in the upper Hudson River. C-2 HONS 010069 2. REVIEW OF HYDROSCIENCE PCB ECOSYSTEM MODEL Hydroscience (1978, 1979) developed a food web model to simulate PCBs in Che Hudson estuary ecosystem. The model was used to estimate the possible effects of remedial acton, to reduce PCB sources in the upper Hudson River, on the Hudson River ecosystem. In addition, the model was used to determine the fate of PCBs in the ecosystem of the Hudson estuary. These tasks were accom plished by analyzing the existing PCB data on the water column, various portions of the food chain and the striped bass, within the modeling framework. Projec tions of expected reductions were made and compared to the existing action level of 5 ug/g and the proposed action level of 2 ug/g in fish. The analysis framework upon which the food web model was developed is at the state-of-the-art stage. With the full utilization of available data during th study period, the model provides the best estimate and range of charge in PCB levels in the Hudson estuary ecosystem which will result if the PCB water column concentrations are reduced. The Hydroscience model was developed based on the fundamental mass balance principle in a deterministic fashion. The model has a solid scientific basis as well ss sound engineering practicality. Of course, each model has its limi tations. The Hydroscience model is no exception. The reports clearly describe the model assumptions and the associated limitations. As a result, it should be noted that the results from this modeling analysis are not meant to recommend any remedial actions. Instead, the modeling report indicates the necessity of a systematic data collection process program to detail the PCB concentrations in the sediments, water column, and biomaas of the estuary is needed so that an additional basis will be available for estimates of the fate of PCBs. Some key conclusions from the modeling analysis help to put the remedial action into perspective in terms of PCB levels in fish. Projections indicate that if a concentration of 0.01 ug/1 was obtained in the estuary, as a re sult of remedial measures, then the striped baas body burden of juvenile and 4-year-old fish would decline to 4-8 ug/g depending on the assumed excretion rate. Older fish under a "worst case" would not decline below 15 ug/g. The C-3 MONS 010070 response cine Co reach these levels is estimated to be 2-4 years from the tine reduction in water concentration is accomplished. Significant reductions in the PCB levels in the striped bass would accompany the assumed concentration of 0.01 ug/1 in the estuary water column. However, the results indicate the virtual impossibility of reducing striped bass body burdens over the near term to Che level of 2 ug/g (the proposed action limit) due to the potential for high bioaccumulation in the striped bass and the ubiquitous presence of PBCs. Based upon the above conclusions, it is seen that the benefit of remedial actions (such as dredging) would not be immediately realized in fish. 3. CONCLUSIONS OF THE REVIEWS Based on the LMS modeling results, dredging is expected to offer reduction of PCB transport into the Hudson estuary. However, the effect of dredging would not be immediately realised in fish in the estuary. In fact, the response time in fish upon extensive reduction of upstream PCB sources may vary from a year to perhaps less than a decade. However, significant evaporative losses, estuary sediment burial, and slow diffusion rates in sediment mey shorten this response time. Compared to the No Action alternative which is estimated to take longer than at least a decade to flush out PCBs from fish, dredging offers a substantial reduction of response time, if not immediately. The conclusions on fish recovery are based on the water column PCB concen trations in the estuary which, in turn, depend on the PCB transport load from the upper Hudson River into the estuary. The conclusions, therefore, hinge on Che predictions of PCB transport. It was concluded earlier that the PCB transport model still needs refinement with additional calibration. It is recommended, therefore, that effort should be expended to construct a rational and cradible analysis of the transport and ultimate face of the PCBs in the astuarina watar column (diaaolved and particulate), the movable bed sediment PCBs, and the PCBs in the sediments, in order to estimate water column response times in tha actuary under different control strategies. C-4 HONS 010071 Continued work is necessary to further refine the food chain model and striped bass model as the data become available, in order to provide a better understanding of PCB transfer in the ecosystem, and to improve the ability to forecast PCB responses under different environmental controls. It is recommended that remedial action be taken to remove the PCBs in the upper Hudson River. Until then, flow control should be implemented to mitigate the storm effects which would resuspend the PCBs and further disperse the PCBs into the estuary. In the meantime, field monitoring should continue to expand the data base and to provide understanding of the problem in the Hudson River and estuary. HONS 0X0072 APPENDIX D Cost Estimates for In-River Containment of Hot Spots and Covering of Remnant Deposits MPI (written communication) March 16, 1981. The cost of rock diking around hotspots 28 and 35; and sheetpiling. Memorandum from J.A. Bedard, Engineer, Malcolm Plmie, Inc., White Plains, New York to Howard Schwartz, Project manager, WAPORA, Inc., New York, New York. Mulligan, J.B. (written communication) March 6, 1981. Cost estimates for clay cover at remnant deposit sites 3 and 5. Correspondence from J.B. Mulligan, Engineer, Malcolm Plrnle, Inc., White Plains, New York co R.F. Thomas, Project manager, Malcolm Plrnle, Inc., White Plains, New York. MPI (written communication) April 22, 1981. Cost comparison for dredging and alternatives to dredging; cost for incineration. Memorandum from J.A. Bedard, Engineer, Malcolm Plrnle, Inc., White Plains, New York to Howard Schwartz, Project manager, WAPORA, Inc., New York, New York. MOMS 010073 MALCOLM PIRNIE, INC. Confuting Environmental Engineers jt 3 10002h91C4o/0e9p4d-2rM10*0Park Dflv*. Whil* *i*n Y 11 12200O Compvttt Oil** W**|, AIMny. M Y 519 459-7904/ 44125O SOW Con** MoM. Cuyahoga mu, onto 210 041-5430> 014 000-4903O 0101 Buten Btvtj . ColumOut. Ohio 43229 / D S 30iS Abooii Rom. Ouiimo. n v 14219 930014 590 5011 23000110/420-1300 a Hidvn Blvd . Newport N*we. W /- D 100 baannow*' 0>r ParMlua. H J 07002 1017 19<03301/0404400 a J*rw> f K*nn*dy ShrO , Phiimipn.*. P* 715/344-0172 O 037013.73O47M-53fg9i0* An* SiiMr Soring. MO 29910 300 South 2} Si <Su>t* 2'2) B"rHr>yim ai* 39733 2350500923-9131 020200/322-0513 Hollywood BN Hollywood Pi* U To: HAfotA_____________________ Jit Eas* 43ri -St,________ __ tUuL.pL, -Mi---------- ____________________ lemi___ Attention Mn dauarJ ``irLmu-fa AliltfihJi h hsrJysuj ; mir far _____ I_____________ GENTLEMEN: etftfsS We are sending you II Enclosed Q Under separate cover via B Mail Messenger, the following items. shop drawings prints data sheets specifications sketches brochures Our action relative to items submitted lor approval has been noted on the drawings COPIES / 1 / PREPARED BY MFr REFERENCE NO UK Hrr_________ DESCRIPTION Ltlkr fro*, tf IK**** fo J6 4VZaJ4 rar+s 3duUi 4-fn/ti, Cc-4 )________________ J 1Menu fnm JA0 h M/iit/t (lfn.tr1) tx fa ai ruck, liking 3*J (Th-4) Hit*!- A-j Tfi 1 4/lljn Pi fas/ ", MFf ?|V<|- 3t7 H,Trifi Istirirpia- iislu_______________________ . , THESE ARE TRANSMITTED AS CHECKED BELOW: As requested For your use For review 4 comment For your information Approved Approved as Corrected Revise and Resubmit Not Approved Remarks: Resubmit_____ copies for approval Submit____ copies for distribution Returncorrected Prints Copies to: tFlUr+a Sc.'rluAy; j&Qtiatt D-l HONS 010074 3z3Q MALCOLM PIRN IE. INC Inter-Ottlca Correspondence ' R.F. Thomas To: ...... J.B.* Mulligan From: !. Cost Estimated for Clay Cover at Subject Remnant Deposit Sites 3 and 5 Date: .... V6/81_ As requested by Judy Bedard, we have prepared a cost estimate for covering the above referenced remnant deposit sites to reduce PCB volatilization and the percolation of surface water into the sites. The estimate is based upon the following criteria: o The minimum depth of clay cover practical is 18-inches; o To prevent the cover from drying out and cracking, a 12-inch thick layer of material suitable for establishing turf will be placed over the clay cover: o The areas will be seeded to wild grasses; o The face of the stone fill bank and channel protection can not be effectively sealed as it must drain with changes in river depth; o Two existing drains under a railraod spur at Area 5 presently discharge onto the site and should be extended across the site to the river using good drain pipe or a paved ditch; o The access road at Area 3 is still useable without acquiring a new easement. o Surface waters flowing onto both sites from the highlands away from the river does not have to be intercepted and carried around the sites but can be carried over the sites as sheet flow. JBM;mhn D-2 . HONS 010075 tuutCT----------------------------- Cay oe- corps ALEA 3 (&-8 Acres) MALCOLM P1RNIE, INC. 2 COflPOftATC PAflK OKIVE WHITE PLAINS. NV 10602 SMUT NO Of JOB NO.__________ 6sfimr>+'Cj+ for Q*ij Ctrtr = trco 7^*3 <&<s include. NY5pC_ COS?* for ptrottks, publ't hearings, or project adninnfrohen . Alla 5 ( S Acres) Sshmoie of Cost for CJaij Co'ftr * ^80j frfrQ "TIijj cos <u+ irctj.dc Al/50C Costs for permits / public h&fnntj3 ' praj <! if sdministrft, <*.. Cojfs for Coverithese areas unite organic trafenot and providdfa fencedro*nd each area tim? keen calculated Urdu- -fU reicopir^ project to 6t 6 oo.tnro. All of ikoot arc Current Costs D-3 MOMS 010076 MALCOLM PIRNIE, INC CONSULTING ENVIRONMENTAL ENGINEERS /T\ 7 April 17, 1981 Mr. James G. DeZolt, Project Manager Hudson River PCB Reclamation Project N.Y. State Dept, of Environmental Conservation 50 Wolf Road Albany, New York 12233 Dear Mr. DeZolt: This will summarize cost estimates prepared by Malcolm Pirnie, Inc. for several alternatives considered in the Hudson River, PCB Reclamation Project. 1 1. Rock Dikes or Sheetpiling (Hot Spot 35) a) Hot spot dredging of 27,250 cu. yd. containing 2,090 lb. PCB has a 1980 dollar cost of $440,000 for typical second season dredging. This includes, dredging, transport and return flow treatment. b) Several dike (or sheetpiling) configurations were evaluated. Costs (not including annual mainten ance, access or engineering and administrative costs) ranged from $370,000 to $510,000 (1980 dollars). Further evaluation will be required to determine the most feasible sections. See attached Bedard memo to WAPORA, 3/16/81 for details. 2. Top dressing and fencing of remnant deposit areas 3 and 5 is estimated at $200,000 plus contingencies, engi neering and administrative costs (page 20, Scoping Report, March 1981) . C-4-1 2 CORPORATE PARK DRIVE WHITE PUUN& N.Y. I0ME M4**21a 0-4 HONS 010077 MALCOLM PIRNIE, INC 3. Costs for clay cover and fencing at remnant areas 3 and S are given on page 3 of the Response to USEPA Comments transmitted to Mr. Manning by Mr. Thomas's letter of March 26, 1981. The value for clay cover for area 3 given on page 3 should be corrected to $400,000. The cost for clay cover for remnant deposit area 5 is $180,000. 4. A preliminary estimate of cost for a rock blanket to cover in-place hot spots is $160,000/acre of river bed covered. This system is quite prelimi nary and will require extensive further analysis to prove feasibility. (See attached memo TDV-4/13/81.) 5. The cost of incinerating two million cu. yds. of river bed material using current multiple hearth technology is on the order of $200,000,000. Very truly yours. Richard F. Thomas, P.E Project Manager RFTihkh cc: Robin Rohn D-5 HONS 010078 at.. SUBJECT MALCOLM PIRNIE, INC. 2 CORPORATE PARK ORSVE WHITE PLAINS. N.Y. 10602 Hcno SHEET NO--L O...S?____ job no. -Us. ~//<ru la \rJkCof-k FV.oH'. Ja 6CaiU CHauJauI Pitihe sueer/T?e cost of A>c.c. Oikiwc Aeouwo riorjAors- .20 awc 3? ; awc ilipo He. KACJ51J3 "SOI "'-ATS.J A pgumMAg-i corr estimate Pas ecoH Oowe ow t&o AtrczpATNes To tfoT 3aot oecoS'ioo .` Tie. use op a PahMi zoo*. Di<e /kcw<* -rve eooe or Tie Hot seer -n> /'Ac/e.-rr /ce Tcsue. awo rut.autenet. Tie use op ouer.rpii.iiui re/, rue iamb /Uasops. . "iSe FMPosc of * esru&ie WAS to oere/Mifie <e empz. hetubq or CbtifAuJejT wao jtiesrA^jTSnu.y cess tcttl'/ TUAtj De.ec<sifii ~me hotspot, foL Txe tut-fna or This csriHtTe Pr ay waj otescu re/, scuc/m, tews: <***,* Tr a 4 Dt^'i/jATfo mctuw/0 auo Tieeeroit H4o AU*u> te.icr.iry ne. eextort t,. Tr ues Atone ne huoscu Give/. dawc. avo necereex /.coaxes Di'WA owty amw owe iioe. fr ucs CoMftereLi ojr or rue NA/xtntMtt o<ww ct . PcCutAitirxf Cs-Pmatc-s Pot. hot j/or TO ytCLO me Foiuuieiun pernor, /. Dacca iw? ST'tso cuj l/lcfuAti 3**1 , truAjpu** la S,lt (jono r P(P>) Cost 0080 Poihri) ^321,000 " 5*S,(MrO HONS 010079 D-6 7H-4- Y..Zp. CMHDVfct SUBJECT DAT! .Jlj&JlL AfctKoo MALCOLM PIRNIE, INC. 2 CORPORATE PARK ORIV6 WHITS PLAINS. N.T. 10602 SHEET NO.5__ Of.*?_____ .o.no 3C<, - 32 CoTT AV9fl<1 Anthr',) S. pLACtui S.OCC Oit-inS To Ct-NTAik1 EmTiEJc XT5f0T a.) 5'ft -Top ujiam of Oik ?uc.eo root foeae *37?, coo b) to Ft Tof uiotw oP Oicfi PLAC.EO flat* oW&e oC Skau. Te.ui.t- C.) /6 FT TSF OnOTO OF 0/E Place0 F'e.on TEuc.cs 434, ooo / 5b 9, ccn 3. 5<F5ce swcerF/uFG A/0 `SEAf-iOO * 422, o-eo 'These Cotrs Oo hot inzuocc h/uit:-ja<jcf, xecsrs^ of. djc.wp.kejnc Costs. HONS 010080 d-7 ik.Tbl Y..JJ2.OATS 31 CHKD.0Y---------- QATB.. ................. MALCOLM PIRNIE, INC. 2CORPORATE PARK DRIVE WHITE PVAIN5. N Y. 10602 usjcct..... Tq.^Ctu (j&NfWEMT^;..... ......................... tiMLSIsSL. SHUT NO......! of____2 job no. ..,,j24.6!.t. 22r..l..... .. KP/-MeUT 0P flCTLvC Trttldic ftCJXi LTOWfi. /J/78 I+OT SPo7 C Tko*l&* tuAvuO fo0 ^OVU - STouE *H.oc /roro ^ ^.Oo/r5N T AfeCic c?l /prMo /fTr / ti*2* * *: ^t.oo /yji /*1 oo *0 -- Ml.Oo/rf1 * 5P.o/rt1 MieidmL TiAMifocT PlAcertcwr ( A^e.(i5v0- fV\TEClA<_ fKK.Ej-A&J'T HONS 010081 D-8 iv TW_....... 0ATe ..i/lj/sj. CHKO. BY 0 ATB ................ MALCOLM PIRN1E, INC. 2 CORPORATE PARK ORIVE WH1 T* PLAINS. N Y 10602 SH6ITN0....or.......... iL JOB NO. SUBJCCT ................................................................................................................................................................................................. To'rtt CouT 7TACm.p:o.o IsiauO Poo. tfoT sfOTt '`"l-zo - pftoe H_-1 txAL AiL6*i - ZO'-'-.'ioo 1 f.to'p.isco - f.Sci^oo r'^ * 3l'J.oo M* < (l7iv) 1 h.iz/r, * <2.22 ll.oo + |J-/ *i. - i i.lo/f-T1- TaT'AL 6JiT c ('r>9C'1l f0 F"* )( i3-T/FTi-) 1 Zl,W, J'iO I = 21. roo. coo dc-.r / nae *IU. in * */lo, ooo /rtoig. HONS 010082 D-9 MALCOLM PIRN IE. INC. Inter-Offlcs Correspondence To: .... From: . Subject RFThomas....................... Data: ... FCristea....... f.C.:... 266-22-1400 PCB - Hudson River - Dredged Material Incineration Costs 1. Based on the following data: a. Dredged material 30% water & 70% sand/silt by weight b. Solids contain 10% volatiles having heating value of 10,000 BTO/LB c. Total mass desity of 92.8 lbs/cubic foot d. Total volume of dredged material is 2 x 10 cubic yards e. Total time for a continuous operation to be five years. 2. Calculations a. Total weight of dredged material .... 2 X 106 yds3 x 27 ft3 x 92.8 lbs - 5.01 x 109 lbs yd3 ft3 b. Total weight of dry material .... 2 x 106 yd3 x 27 ft3 x 92.8 lbs x .7 - 3.51 x 109 lbs y33 It? c. Loading rate .... 5.01 x 109 lbs 114,000 lbs/hr (Total mass) 8760 hrs x 5 yrs yrs 3.51 X 109 " 80,000 lbs/hr (dry material) 43800 d. Number of Incinerators required .... 114,000 lbs * 23,000 lbs 5 units hrs hrs Note: Ose five incinerators plus one stand-by unit Total six incinerators e. Capital Investment costs for incinerators .... at $15,000,000 per unit, installed Total investment costs - $90,000,000 (Includes escalation through 1984) f. Fuel required .... Fuel required for combustion at 1800F 898 GPM Fuel required for combustion at 2200F - 1533 GPH Total fuel required .... MOWS 010083 D-10 At 1800F - 898 gal x 8760 hr x 5 yrs * 39 x 10 gallons hrs yr At 2200F - 1533 x 8760 x 5 - 67 x 10S gallons Projected average cost of fuel oil during 5 year period $1.75/gal 39 x 10 x $1.75 $68,250,000 gal 67 x 10 X $1.75 = $117,250,000 gal 3. The installation of heat recovery boilers or combustion air preheaters will reduce the amount of fuel oil required significantly. A computer analysis was made, using a preheater to raise combustion air to 800F, that calculated a fuel oil consumption of 214 gallons/hr 214 gal x 8760 hr x 5 yrs 9.37 x 10 gallons hr yr 9.37 x 10 X $1.75 = $16,397,500 gal (fuel savings over 5 year) Estimated additional capital investment costs for preheaters is $15,000,000 installed and adjusted for escalation through 1984. 4. Summary (without air preheaters) .... Combustion Temperature 1800F________ 2200F Fuel required (gal) Fuel costs $1.75/gal Capital Costs: Incinerators Material Handling Equip, costs Estimated Labor Costs 39 x 10 67 x 10 563,250,000 $117,250,000 $70,000,000 $ 90,000,000 S 9,000,000 $ 5,000,000 $172,250,000 $ 9,000,000 $ 5,000,000 $221,250,000 FC/rf cc: RFBonner SCSchwarz JJTansey 0-11 HONS 010084 APPENDIX E Water Quality Data HONS 010005 . Table E-l Classifications and Standards for Fresh Surface Vaters HONS 0 1 0 0 8 7 Table E-2 Water Quality Constituents, Upper Hudson River Cw<U*wli (m/1) ileaalveA Beyyra' fart Mvii4 (i f. i92.ll fci. HI*, aw |4.4 19.1 TImim (N.r. !.) >i.__ R|t.__ He-- 1*4 |.9 (3.9 COD1 Tele) 5*1 W (is T)^ Nltrelei (aa H)1 Heavy Halala (pi/t)* Areealc Cayyar Sectary LeaA Ce.htlea JJ.9 4.9 13.9 I 4 .31 .91 .39 .14 .13 .34 2.9 9.9 9.3 29.9 9.9 9.3 21 <9.3 <0.1 19.9 9.9 9.9 (I rearflat) 1-0 19.9 ti.9 14.3 n t v.s .99 .< .44 .32 19.9 29.9 7.9 13.9 9.9 1.4 9.0 9.9 <9.3 <1-9 2.9 4.4 CArwIw (tat.) CyaalAa 2IC t*43 (I reeAlat) 4.4 (I reaAlef) 19.4 (I rc'IU|) 44.9 Schvylarvtlta 0lll.lrl.MuUs. 7f) 9n, Din. HeM_____ Hea.__ Hi#.__ He-- 13.1 4.4 19.2 (Vntrl.trfi*s(*4.9) Wee. Hie. He-- 14. 19.4 >2.9 3.9 29 2 13.2 I 24.4 12.4 74, I |7.| t) .13 .93 .44 .19 .9) .39 .14 .9) t.19 .19 .9; .31 19.9 29.4 3.9 42.9 9.9 3.7 9.9 4.3 <9.3 <4.13 3.9 14.4 1.4 40.9 9.9 394.4 14.4 9.9 4.4 9.4 12.1 9.4 <9.3 4.4 44.4 4.4 1.4 29.9 9.4 1.4 144.4 14.9 33.4 (41 mr* kiaiirJ/*1 Icrini.il.l (Clave A Crlletle fir... the--tfc 9) A--etlc IHc**1 3.4 at/1 1.4.|/l (3.4 7ar 91 Ceaaat ha lit raAvctlaa Aeletarl--e a( aara. traf. ta heal aae yt. 4.1 a|/1 fatal y 49 *t/I fat vecavaler (|ah 299 iig/1* 349 |*/l* 199 py/l* 399 |i|/l* ** .93 |t|/l ft 9.4 Mi I far aeaa. erye. la aafl velar 199 pt/l 3.9 py/l lat lapalr .991 Rf/| Hah. ar beat aae Tat velera with treater thee 49 a|/l etbellally. la leaa haffereA velar each aa the Maw Rlvar. thaac Malta mII be laveieA. Cilterl-- eeyreeaeA aa a yercanl af the 9i-fc--r LCIfl (that c--ceetratl-- Icthel ta 39 pa-cat af laAlvlAaele, aaleg a aaaaMIva reeMeat ayeclaa). Notes: 1. 9TSBF.C Veter Qaellty far rail laact, Veter Qvallty ilatlatlcal tvwaecy iryact 19-1*71 la f-39-74. (Th--eaa reialte fra# RTSOCC Valer Qeellty Serve IIIeere, av Data itetlat 19/74 ta 4/73). 2. DSG> Veter Reeevrcee Olvltlaa, Albaay, 2), 1171 ta 14)4. Veter Quality Pate, leitw Hear Syatea. 3. IISC3 Veter teeaartea Olvltlaa, Albaay, IT. Veter Quality Bata Vatar Tear Octahar 1974 ta 4eyteal.ee 19)7. 4. State af Rev Verb, Official C--eUatlew CaAea. Rule# acA Heialetlaae. Article 2, fart 741, "Cl--elfleetiaaa eaA ItaaAecAa af Parity." 3. IRtfl, 1174, Qaalltr Crlfrla far Vatrr (yre-yvMIcalf-- ceyy). Source: MPI, 1978a * E-2 MOMS 0 1 0 0 8 8 Table E-3 performance or rehoval ststehs, ro HISSED OR LOST FOR COKPLETS HOT SPOT DREDGING PROGRAM HTDRAVLIC DREDGING OF THOMPSON ISLAND POOL DOT SPOTS CURSKELL DREDGING OF LOWER POOL ROT SPOTS Hydraulic (Thompson Island Pool) PCB Haas (lbs) Clanahall Dredging and Hydraulic Punpout v/Recycle v/o Recycle of Return Flov f Return Flov (Lover Pools) PCB Rase (lbs) Total PCS Itasa Percent (lbs) Total PCB in Hot Spota 105.BOO 64.100 64,100 169,900 100 PCB Hissed by Dredge 2% with Hydraulle Dredging 5% vith Clanahall Dredging PCB Lost In Dredging Process^ Water Colinci Losses 20% of Hydraulic Dredging Pltwt 20% of Clanahall Dredging Plwe . 2.100 420 3,200 3,200 520 520 5,300 3.1 940 0.6 Resettled Losses 80% of Hydraulic Dredging Plisoe 60% of Clanshe11 Dredging Plune PCB Lost in.Return Flov Water at 10 ug/lu; Total PCS Lost to Water Colun^^ Total Hot Spot PCB Hiseed and Loot 1,680 160 580 4.360 2,080 20 540 5,820 2.080 150 670 5,950 3,760 2.2 . 180-310 0.1-0.2 1120-1250 0.7 10,100-10,310 6-6.1 (1) Hydraulic dredging results in 2% of the dredged PCS entrained in dradge pliMtj cUnsheU, 4%. (2) Water treatment plant flow# eatlnated to be 12 ugd and 1.4 agd for thaaa calculations. (3) includes laaas to vatar ealwa during drtdging process, aad laaaaa t# vatar caltam fren raturn vatar flov. Sourcei E-3 TABLE E-4 SUMMARY. BED MATERIAL UEAVY METAL CONCENTRATIONS LOCATION Fort Edward^^-East Channel (RM 194.2-194.3) West Channel (RM 194.3-194.4) Buoy 214 (RH 192.4)^ Thompson Island Pool11 221 (RM 188.4) Moses Kill (RH 189.I)*3*4 SO Darrel Sample 40 Darrel Sample Northumberland (RM 183.5)^ Buoy 212 (RM 192.3)^ As Cd Concentration in ue/e Cr Cu Pb . Ufi__ Ni Ag Zn ND 0.78 9.1 21.2 18.2 0.17 7.4 - NM 50.6 1.0 12.9 18.9 26.7 0.11 8.7 53.2 0.9S 7.7 16.1 19.2 0.10 10.2 52.8 ND 0.46 8.4 19.0 18.5 0.06 6.9 NH 43.3 0.76 23.7 29.9 77.5 0.10 9.9 57.8 2.1 1.1 255 35 150 NM 16.5 NM 150 1.9 27 450 53 375 NM 24 NM 245 4 16 560 100 4 35 825 150 1.2 4.4 42 3.2 NH 6.0 27 25 440 0.1 40 26 360 840 1 41 125 680 180 NM NM NM 180 77 NM NM NM 88 Representative Bed Material Concen trations, Thompson Island Pool IS) 3 30 500 100 500 0.5 30 80 500 ND = None Detected, NM = Not Measured |1] Malcolm Pirnie, Inc., Environmental Assessment-Maintenance Dredging Champlain Canal. Fort Edward Terminal Channel, p. III-21, (1977) (2) Toffleuire, T.J., DEC, Preliminary Report on Sediment Characteristics and Water Column Interactions Relative to Dredging tlie Upper Hudson River. (1976) 13) General Electric Corp., Corporate Research and Development, Laboratory Data Sheet (September 9, 1977). (4) Tofflemire, T.J., DEC, "Duoy 212 Dredging-Update and Conclusions," Memorandum to Mr. Mt. Pleasant, (January 1977) |5) Based on a subjective analysis of the existing data for Thompson Ialsnd Pool as presented above HONS 0 1 0 0 8 9 E-4 Table E-5 PROJECTED INCREASES IN AMBIENT HEAVY ICTAL CONCEimuTlONS FROM DHKOCEilEAD U)SSCR ONLY; UYOKAULIC VS. CUitfUEU PKEDCIl All vtliwi yg/1 cictfl (MccntriliH la bed uUriili, g/| >ylrMlic Dredaa _________Cl--oliel! PraJge ` Eleaeat Arsenic Cadal -- Chrauiun Cuyfier Uad Hcrcury Nickel Silver Zinc Rati--ted Bat!--ted Repreacntative Initial Final Ceecentratlen Increase Increase In led . Abeve . Settling* Abe-- Materials* Aadiient1 2 Factor3 4 Aoblent Eat!--ted Initial lecreaee Above , Aebienl* Rattling, Factor" Catl--ted Final lucre*-- Above Aabient 3 0.1 O.S 0.1 0.2 0.5 0.1 30 0.1 0.3 O.A 1.0 0.5 0.5 500 . 11.A 0.3 5.7 17.2 0.5 1.4 100 . 2.2 0.3 1.1 3.A 0.5 1.7 300 11.A 0.3 5.7 17.2 O.S 1.4 0.3 0.0 0.3 0.0 0.0 0.5 0.0 30 0.1 0.5 ' O.A 1.0 . 0.5 0.5 0 1.1 0.5 0.1 2.1 0.5 l.A 300 11.A 0.5 3.7 17.2 0.3 1.4 Aabient beckground Uvela-caagg end averegt * Eat 1--tod Cwanlative Aabient Honan Mu Cl--I. 0.0 - l.o 0.1- (O.A) l.i 0.0 - 10.0 0.4- O.A) 10.A 0.0 - 2Q.0 5.7 (l.A) 25.7 0.0 - 40.0 l.l- 02.1) Al.l A.O - 300.0 g.7- 04.t) 305.7 O.A 0.1 0.4 (0.5) 0.1 Not ' --enured Not --osured 10.0 - 100.0 15.7 (33.6) 105.7 0.1 1.1 0.5 10.5 1.6 21.6 1.1 41.7 12.6 301.6 0.4 0.1 - 11.6 101.6 NVSDCC Certilicatlon 50 10 50 200 30 2 2500 * 300 1. Beeed an a range ef bed --terial velvet --by JfYSUEC, General Eluldc Cm., end tfalcolv Piraic, Inc. (ce Table 1V-I). 2. Bated mu iu-ailu --Cal level# preaeuted above, 2 --d 4 percent leas catca far IU hydraulic and cl--abell dredges, respectively, sad cwplili dllutlea af (be plu-- ai MOO cfe. ' 3. Derived fir-- 2 jar teats ferfer--d un NorUi'MalerUnd bed --terlals witbeet flecculstlea ar filtratlen af supernatant (Teffl--Ira, T.J., DEC, Pretlelnary Report an Sedl--nt Characteristics aad Water Calunn lataraetlnna Relative ta Omdtlnt the Uiner IlmUaa liver f*r MB Si-SeiSi. IIM.I Bee Append!* F. ' --------------------------------------------------------^............................................*-- 4. Measured at Vatcrlard. IISOB Water Rcaenrcca fiiviaieu, Albany, N.Y. Mater Quality Rata, Hudsen River. 0 6 0 0 T O SNOW ' E-5 Table E-6 Meeauceaeat res Araenlc Cadnlum Chraalua C.,,r Lead ttercory Nickel Zinc CHANCES IN MBIUTT WATCH QUALITY AS A MESUtT OF COtftINCB ESTIMATE* OF tttTIKN FLOW LOSSES AMO ME0GC11CA& LOSSES <AI4. IM1TS yi/1) Hydraulic lr><li ClwbtH Otedio Catfnated Estimated Increase above above Concentration. anblent Irm^ aadiient froa Tata! In return flaw* return flow deedaebead Incraaoe Cstloated Estimated Increaaa above above Concentration . saiblent froa , anblent froa In rclnvn flow1 2 return How dredeebeed Total increaaa Backgrewed Benge, Veterferd Aablont ' MYSDCC Certif icatloa. Standard* 100 *. (.) 0.2 j.j (.}) 100 0.1 (0.0) 0.4 0.5 (0.4) 0.- I.*1 0.5 500 10 0.1 1.1 500 0.5 0.1 0.4 0.0- 1.03 4 50 100 2.0 0.4 2.4 100 0.1 0.5 0.6 o.o- io.e3 10 500 2,000 300 20 . 10 40 6 0.4 5.7 15.4 1.1 40.3 5.7 11.5 0.0 0.4 500 2,000 . 300 20 0.5 2 0.3 0.02 . 4.6 1.7 1.6 0.0 1.1 3.4 4.1 0.02 o.o- 10.o3 0.0- 00.o3 4.0-300.o3 0.4- o.o3 50 200 30 2 25,000 ' 3,000 500 60 0.4 410 5.7 64.4 25,000 3,000 25 3 0.5 26.3 Not aeaaured 25,000 4.6 11.7 10.0-100.o' 300 Itfimiftii 1. Itid m NY9VCC cirlltlMlUa ! NYSDOT 10 year Mlnitauci dredging pr|iM forCbiaflaU Barge Canal and IMim Rlvar. 2. USCS, Water Miaurcta Dlvlilaa. NtWaao Siver at Waterford, N.F, tout! A Bridge, Water Year October 1174 to September 1177, 2. USCS, Water Bcceurcea Division. Water Quality Surveillance Network, Trace Meta) Analysis. Italian 11-003 at Vaterferd. April 1175 te July 1171. 4. Without carbon adserptlan Ircalaent of return flow. Carben adserptlan aatinatee far FCS In paresthesia. 6 0 0 1 0 SNOWt E-6 TABLE E-7 NATIONAL INTERIM PRIMARY DRINKING WATER REGULATIONS Subpart B-Maxiraum Contaminant Levels Section 141.11 Maximum contaminant levels for inorganic Chemicals. (a) The maximum contaminant level for nitrate is applicable to both community water systems and non-community water systems. The levels for the other inorganix chemicals apply only to community water systems. Compliance with maximum contaminant levels for Inorganic chemicals is calculated pursuant to (141.23. (b) The following are the maximum contaminant levels for inorganic chemicals other than fluoride: Level, milligrams Contaminant per liter Arsenic................................................................................................................................ 0.05 Barium................................................................................................................................... 1 Cadmium................................................................................................................................. 0.010 Chromium................................................... s....................................................................... 0.05 Lead........................................................................................................................................ 0.05 Mercury................................................................................................................................. Nitrate (as N)................................................................................................................ 0.002 10. Selenium................................................... ......................................................................... o.Ol Silver.................................... ............................................................................................. 0.05 (c) When the annual average of the maximum daily air temperatures for the location in which the community water system is situated is the following, the maximum contaminant levels for fluoride are: Temperature Degrees Fahrenheit Degrees Celsius Level, milligrams per liter 53.7 and below 53.8 to 58.3 58.4 to 63.8 63.9 to 70.6 70.7 to 79.2 79.3 to 90.5 12.0 and below 12.1 to 14.6 14.7 to 17.6 17.7 to 21.4 21.5 to 26.2 26.3 to 32.5 2.4 2.2 2.0 1.8 1.6 1.4 Section 141.12 Maximum contaminant levels for organic chemicals. The following ere the maximum contaminant levels for organix chemicals. They apply only to community water aysteaa. Compliance with maximum contaminant levals for organix chemicals is calculated pursuant to { 141.24. HONS 010092 E-7 Table E-7 (Continued) Level, nilligr per liter () Chlorinated hydrocarbons; Endrin (1, 2, 3, 4, 10, 10-hexachloro-6,7-epoxy-l,4, 0.0002 4a 5,6,7,8, Sa-occahydro-l, 4-endo, endo-5, 8-dimechano naphthalene). Lindane (1, 2, 3, 4, 5, 6-hexachlorcyclohexane, gamma iaoner). 0.004 Methoxychlor (1, 1, 1-Trichloroethane). 2, 2-bis 0.1 (p-nethoxyphenyl). Toxaphene (CQH.SI -Technical chlorinated camphene, o/-o9 percent chlorine). 0.005 (b) Chlorophenoxy: 2, 4 - D, (2, 4-Dichlorophenoxyacetic acid). 2, 4, 3-TP Silvex (2, 4, 5-Trichlorophenoxypropionic acid) 0.1 0.01 Source: U.S. EPA, 1976 E-8 HONS 010093 TABLE E-3 NATIONAL INTERIM PRIMARY DRINKING WATER REGULATIONS <143.3 Secondary Maximum Contaminant Levels. The Secondary Maximum Contaminant Levels for public water systems are as follows: Contsminant Level Chloride........................................................ Color............................................................... Copper............................................................. Corrosivity................................................. Foaming Agents......................................... Iron................................................................. Manganese..................................................... Odor................................................................. P...................................................................... Sulfite.......................................................... Total Dinolved Solid! (TDS).... 250 mg/1 15 Color Units 1 mg/1 Non-Corrosive 0.5 og/1 0.3 mg/1 0.05 mg/1 3 Threshold Odor Number 6.5-8.5 250 mg/1 500 mg/1 These levels repreeent reasonable goals for drinking water quality. The States may establish higher or lower levele which may be appropriate dependent upon local conditions such as unavailability of alternate source water or other compelling factors, provided that public health and welfare are not adversely affected. Source: U.S. EPA, 1979 MONS 010094 E-9 APPENDIX F The Hudson River Fish Fauna Smith, C. Lavett. 1977. The Hudson River fish fauna. In: McKeon, Warren H. and Gerald J. Lauer (eds.) Hudson River ecology. Proceedings of a symposium. Hudson River Environmental Society Paper No. 32. 12 pp. HONS 010095 THE HUDSON RIVER FISH FAUNA C. Lavett Smith The American Museum of Natural History, New York Because of its morphometry and geographical location, the Hudson River drainage is inhabited by extraordin arily rich fish fauna. About 120 fish species have been recorded in the literature as occurring in the Hudson River system and recent collecting has pushed the-total to more than 130. In spite of the changes brought about by human uses and abuses of the river, there are more different kinds of fishes in the Hudson now than there were when Henry Hudson arrived in 1609. There have been a number of successful introductions, but there are no convincingly documented examples of any species becoming extinct, although some have not been reported for a long time and the ranges of others have been severely restricted. HONS 010096 INTRODUCTION Like other large rivers, the Hudson has been badly ne glected and our knowledge of its fishes is far from complete. Large rivers are singularly difficult to sample because depth and current prohibit some types of gear and rough bottom restricts the use of others. Furthermore, there has been a lack of interest -in the . fishing resources of the Hudson for political and eco nomic reasons so that little effort has been directed to the scientific study of its fishes. . The Hudson River fish fauna is a young one. The entire drainage was covered by glaciers during the Wisconsin glacial interval, hence the fauna can be no older than 10,000 years. It has, however, been pointed out that sections of what is now the Hudson Canyon would have ' been uncovered by Pleistocene sea-level-lowering and may have served as a refugium from which some fishes could have repopulated the present-day basin as soon as the glacial front began to retreat (Cole, 1967). Gla cial drainage patterns also provided access to the Hud son basin from the Gulf of Mexico drainage and this, more than any other single factor, accounts for the richness of the Hudson River fish fauna. HUDSON RIVER GEOGRAPHY AND FISH HABITATS The upper Hudson, from its source streams in the Adiron- dacks to about the Glen, is a fast-flowing cool, oligo- trophic stream. -.'The granitic rocks are poor in calcium and relatively insoluable so that minerals are limited. This region lies within the boundaries of the Adiron dack Park and is well forested so that runoff is natur ally controlled. ' Between the Glen and Troy, the River flows more slowly and the underlying rocks provide more nutrients. Be tween Warrensburg and Troy, a series of natural water falls has been augmented and harnessed for hydro and hydroelectric power, which has created a series of slow water environments. Major tributaries, including the Schroon, the Sacandaga, the Batten Kill, the Hoosic and the Mohawk, provide still more diverse fish habitat. Here too, the Hudson is joined by two major canals, the Champlain-Hudson Canal (opened in 1819) that connects with the St. Lawrence River and the New York Barge Canal the present-day version of the Erie Canal which first *QNS 010097 F-l connected the Hudson with the upper Great Lakes in 182S (Hubhs and Lagler, 1947:6). From the Troy lock to the Verrazano Narro\ s, the Hudson River is a long, narrow tidal estuary. Except for the Cornwall to Verplanck section where it passes through the Hudson Highlands, it proceeds southwards in almost a straight line. All of the estuary is tidal, but the salt wedge extends upstream only to the vicinity of New burgh, its exact. limit varying according to the amount of freshwater coining downstream. In spite of its straightness and austere appearance on the charts, the lower Hudson presents a wide spectrum of fish habitats. Islands, tributary streams, shallow flats deep channels and bays that have been partially walled- off by railroad beds provide rich and varied cover for fishes-and their-food-organisms.- * Much of the shoreline is protected by stone rip-rap that provides excellent she ter for small fishes. - Although it would appear that the Hudson River is.divided into well-defined fish habitats, the fishes themselves do not recognize such sharp distinctions. While it is gen erally true that the small creeks of the Adirondacks are dominated by brook trout and blacknose dace, and the lowe Hudson contains such marine species as anchovies and bluefish, there are no really pronounced faunal breaks. Many species have a wide range in the River - the yellow perch white suckers and golden shiners, for example, are taken in small Adirondack streams and also in the main River at Haverstraw. Most species have preferred habitats in whic! they reach their greatest abundance and marginal habitats where they exist as minor components of the community. Thus, a complete study of their distribution must also in clude information on relative and absolute abundance. Un fortunately, it is frequently the unusual or stray indiviual that finds its way into museum collections, and for this reason a plot of recorded occurrences often does not give a true picture of the species range. FISH DISTRIBUTION PATTERNS MARINE AND EURYHALINE FISHES . Numerous marine fishes enter the lower Hudson and travel upstream varying distances depending on their ability to tolerate freshwater. Some are present throughout much of HONS 010098 F-2 the year;, others come in only at certain seasons. Still others are strays or wanderers'and are recorded only sporadically. In theory, almost any species from the North Atlantic, or even the West Indies, might at some time enter the lower reaches off" the Hudson, and new . records will appear as .long as we continue to study the River. A. Marine.and Euryhaline Species Commonly'Taken in the ' Hudson ... ;.... .. . _ : r:,e jack crevalle, Caranx hippos, is an example of a marine fish.that is frequently taken in the River during later summer and early fall. -.Like the bluefish. (Pomatomus saltatrix), the weakfish (Cynoscion regalis) and the silver perch (Bairdiella.chrysura), it appears, to enter the River in.numbers only when young. Most'of the'jack crevalle are less than 6* long and .presumably are', less than one.year old. . . ". Other marine and brackish water fishes'common'in the ' lower Hudson are:; . . .. . . ; .. . , Brevoortia tyrannus . Atlantic" menhaden! .. . ' .. Anchoa mTtchllli , .. Bay anchoVy ,. Strongylura marina .. Atlantic needlefish']. . : .; Fundulus heteroclitus Mummichog... ' ` Menidia menidia.. . .. . ' Atlantic silverside' ' ' Menidia beryllina' " ` Tidewater silverside Syngnathus fuscus ..... ' . Northern'pipefish Apeltes quadracus . Fourspine stickleback . ' Morone americana White, perch ' . ' '. . Pomatoraus saltatrix' '. Bluefish'.....,', . ' Lut1anus~qriseus. . - ' Gray; snapper. ' ' , ... ' Leiostomus xanthurus Spot '. . ' Mugil cephalvis . Striped, mullet - ' . ' . ' .Paralichthys dentatus " Summer.flounder (.fluke) . ,. Pseudooleuronectes ' '. -'. . " americanus....... . Winter flounder. ... ' ,1 '. . ' Trlnectes macu'latus ' Hogchoker-!. '~ * :' Of these, Aoeltes quadracus,. Morone americanus. and Tri- nectes maculatus are able to' tolerate freshwater for ex tended periods and range well upstream.,, Lutjanus griseu - is a West Indian species, once kecordfed from near Tarry- town (Boyle,. 1968:33) .. ....- - HONS 010099 F-3 B. In contrast to these regular inhabitants, some other marine species are rare or sporadic in the lower Hudson ana have only been taken on one or a few occasions: Carcharhir.us obscurus Raia laevis C-i-Ts ~or.-'ja Fierlucclus bilinearis f ur.culua ma-.tlis Membras rartrnica Kisuoca.T.rus erectus Pur-.ritius eur.aitias Gasterosreus aooleatus hvoxocep.ia^u 3 OCLO- cecemstj-nosus Rachvcer.tron canadum Lutianus criseus KjLcrooocon ungulatus Bearilus triancantnus Dusky shark Barndoor skate Atlantic cod Silver hake Striped killifish Rough silverside Lined seahorse Ninespine stickleback Threespine stickleback Longhorn sculpin Cobia Gray snapper Atlantic croaker Butterfish - C. Some of the best known Hudson River fishes are diadromous forms that spend part Of their life cycle in fre.shwater and part in salt. The American eel, Anguil la rostreta, is a catadromous species that must return to the sea to spawn. Juvenile and adult eels are ex tremely abundant in the lower Hudson and even up into the Mohawk River, where there was formerly a consider able fishery for eels. Three, herrings, -the .American shad (Alosa sapidissima) . the blueback (Alosa aestivalis) and the alewife (Alosi~-~pseudoharenqus 1, are well known for their spring spawning runs, as is the striped bass (Morone saxatilis). During the late fall and winter months, the tomcod (Microaadus ' tomcod) moves into the River to spawn. Other anadromous fishes are: Petromvzon marinus Acipenser brevircstrum Acioenser cxvrnvnchus Osrr.erus mordax Sea lamprey Shortnose sturgeon Atlantic sturgeon Rainbow smelt Although there are a few early records of Atlantic sal mon, Selmo salar, entering the River, it is doubtful that the Hudson was ever a salmon stream (Boyle, 1969:39-41). F-4 MOMS 010100 FRESHWATER FISHES The freshwater fishes of the Hudson River pose some interesting distribution problems. Introductions - both deliberate and accidental - occurred early in our history, in many cases long before there was any attempt to determine the original ranges of the spe cies in question. - A. Lake-Dwelling Species The lake trout (Salvelinus namaycush Walbaum), the round whitefish (Prosopluro cylmdraceum Pallas), and the lake whitefish (Coreqonus artedii Lesueur) are apparently native species, having invaded the region through glacial outlets and lakes at the end of the Pleistocene. Their habitat requirements restrict them to lakes rather than streams. B. Wide-Ranging Stream and River Species The following list includes species that-are generally distributed on the Atlantic coast and occur in stream drainages on each side of the Hudson. Their presence is, therefore* expected and, in general, they offer no clues as to the corridor by which they invaded the Hud son River drainage. Lampetra lamottei Dorosoma cepedianum Salvelinus fontmalis Esox niger Esox americanus americanus Erlmyzon oblonqus Catostomus commersoni Hypentelium~iqricans Notemigonus crysoleucas Exoglossum maxillinqua Semotilus corporalis Semotilus marqarita . Semotilus atromaculatus Rhinichthys cataractae Rhinichthys atratulus Phoxinus eos PimephaTcs notatus Notroois hudsonius American brook lamprey Gizzard shad Brook trout Chain pickerel Redfin pickerel Creek chubsucker White sucker Northern hog sucker Golden shiner Cutlips minnow Fallfish Pearl dace - Creekchub Longnose dace Blacknose dace Northern redbelly dace Bluntnose minnow Spottail shiner F-5 HONS 010101 Notroois cornutas Kotroois bi frenatus Hvbocnathus nuchalis recius Ictalurus nebulosus Ictalurus natalis Pcrccosis emiscomavcus Fundulus diaohanus CulaeaTnconstans Enneacanthus obesus Leoomis auritus Leoomis gibbosus Perea flavescens Stitostecion \Ttreum vitreura Percina caprodes Etheostoma olmstedi Cottus cognatus Common shiner . Bridle shiner"- Silvery minnow Brown bullhead Yellow bullhead Trout-perch -- Banded killifish Brook stickleback Banded sunfish Redbreast sunfish Pumpkinseed Yellow perch Walleye Logperch Tessellated darter : Shiny sculpin The gizzard shad, Dorosoma cepedianum, is of particular interest because it has only recently been taken in the River (Dew, in press). Whether it arrived via the Cham- plain-Hudson Canal, the barge canal or along the coast is not obvious. ' "' ~ C. Northern Species Reaching Their Southern Limits In Or Near the Hudson - Some of these species occur only in headwater tributaries and --were presumably able to become established through . glacial outlets as the ice receded. Probably they are habitat (temperature?) limited. The range of Hyboonathus hankinsoni HubDs, for example, extends from the Missouri drainage of Colorado, Wyoming and Montana across Nebraska and The Dakotas, Wisconsin, Iowa, Northern Illinois, Michigan and Southern Ontario to the Adirondack region of New York (Bailey, 1954). Others have even broader ranges. The longnose sucker, Catostomus 'catostomus Forster, occurs in eastern Siberia as well as most of Canada and the Nor thern United States. Esox luclus Northern pike Catostomus catostomus Longnose sucker Moxostoma macroleoidotum Shorthead redhorse Couesius plumbeus Lake chub - Phoxinus neooaeus Finescale dace , PimephaTes promelas Fathead minnow HONS 010102 F-6 Hvboqnathus hankinsoni iintrools heterolepis Notropis heterodon Brassy minnow Blacknose shiner Blackchin shiner D. Specie3 That Reach Their Northeastern Limit in the Hudson There are species of the Atlantic coastal plain that have not extended their range north or east of the Hudsc' Valley. Possibly they are temperature limited, but other explanations cannot be ruled out at this time Dmbra pygmaea Notropis chalybaeus Ictalurus catus Noturus Insignis Noturus qvrinus~ Acantharchus pomotis Enneacanthus gloriosus Eastern mudminnow Ironcolor shiner White catfish Margined madtom Tadpole madtora Mud sunfish Bluespotted sunfish E. Two other species, the rosyface shiner (Notropis rubellus) and the spotfin shiner (Notropis spilopterus) have wide ranges in the Mississippi and Great Lakes drainage and on the Atlantic coast when N. spilooterus occurs in the Susquehanna, Delaware and Hudson basins, and N. rubellus is found south to the James River.They have not, however, extended their ranges to the east. F. Introduced Species Species that are not native to Northeastern North Amer ica are clearly introduced, but there are some species that occur in nearby drainages and may or may not have been introduced. I believe that the following species were intentionally introduced into the Hudson River system. . . Salmo salar Salmo trutta Salmo gairdneri Carassius auratus Cyprinus carpio Micropterus dolomieui Microotcrus salmoides Pomoxis annularis Pomaxils niqromaculatus Atlantic salmon Brown trout Rainbow trout Goldfish Carp Smallmouth bass Largemouth bass White crappie Black crappie F-7 HONS 010103 Ambloolites ruoestris Lcoomis ir.acrochi.rtis Rock bass 'Bluegill The restricted occurrence of the green sunfish, Leoomis cvanellus. in the New Croton Reservoir, and the vermouth f.goon is oulos us, in the Sawkill near Anandale, stronqlv sugcests .that they were accidentally "Introduced (Greeley 1937:102-103). Finally, there are several species whose presence in the Hudson drainage may have resulted from their moving through canals. Most canals, however, follow ancient' stream connections and glacial outlets, and for this rea son we cannot always be certain that the species was ab sent before the canal was built. Thus, Gibbs (1963:525) interpreted the presence of Notropis analostanus in the Mohawk-Hudson as "evidence in favor of a formerly wider distribution in New York, for the species probably en tered that river system when it was the outlet for the waters of glacial Lake Lundy or Lake Iroquois." In con trast, Snelson (1968:796) states, "There are two alter nate explanations for the widespread occurrence of Notropis atherinoides.ln the Mohawk-Hudson system. Trans fer could have been via the Mohawk outlet which shunted water from glacial Lake Vanuxem down the Mohawk-Hudson Valley. . . . Just as likely, however, is the hypothesis that Notropis atherinoides more recently entered the Hud son drainage via the'Erie Barge Canal system which was opened as a continuous waterway connecting the Finger Lakes -'Lake Ontario-drainage with the Mohawk-Hudson- drainage in 1825." Western species that probably gained access through the Erie Canal are: Umbra liml Notroois atherinoides Clinostomus elonaatus Labidesthes sicculus- Etheostoma biennioiaes Central mudminnow Emerald shiner Redside dace Brook silverside Greenside darter Species that could have entered through the Erie Canal or through the Champlain-Hudson Canal,since they occur in the St. Laurence River. Noturus flaws Morone chrvsops Etheostoma flabellare Stonecat White bass Fantail darter ` F-8 HONS 010104 The hornyhead chub, Nocomis bi_cutta_tus, reaches its eastern limit tin the Mohawk system, where Hubbs and Lagler (1947) considered it to be native. Three species are known only from western tributaries of the lover Hudson with a few records from the River itselfP They are Sotrosis amee.-ius, Notroois analostanus and Perci.na peltata. Tnese may have entered the Hudson drainage ay stream capture where the Wallkill reversed its flow from the Delaware drainage to the Hudson drainage. One must also consider the possibility that they gained access through the Delavare-Hudson Canal. SU.TARY In addition to its well-known commercial and sport fishes, the Hudson River basin contains a wide variety of smaller fishes that serve to indicate the dispersal routes through which the fishes repopulated the River ' after the retreat of the last Wisconsin glacier. More than 100 species live in the Mohawk-Hudson system and twenty-two additional species have been reported so infrequently that they can be considered visitors, al though our present knowledge is quite sketchy and this juugement may be modified in the near future. The origin and distribution of Hudson-Mohawk fishes can be summarized as follows: MtwINI AND 3ii WATlR SPli 1ES A. Common (Residents at least part of the year) B. Rare (Transients) C. Diadromous FRESHWATER SPECIES A. Lake-Dwelling Soecies B. Wide-Ranging Species C. Northern Species D. Atlantic Drainage (reaching northern limit in the Hudson) . E. Western (Mississippi Drainage) F. Introduced Species 1. deliberately introduced 2. accidentally introduced 3. canal introduction f Species 20 22 10 * 34 9 ~ 7 2" 11 2 F-9 HONS 010105 a. Erie Canal b. Champlain-Hudson or Erie c. Erie Canal or native d. Kallkill or Delaware-Hudson Canal 5 3 1 3 133 While introductions have increased the faunal list, other human influences (such as impoundments and eutro phication due to domestic sewage and other fertilizers) have tended to favor the most tolerant species at the expense of others. The concept of diversity should in clude equitable distribution of numbers. Although there are more kinds of fish in the River today, the over whelming preponderance of a few species (carp, white perch, striped bass, sunfish) means that the fishes are actually less diverse than they were in primeval times. Lower diversity is generally a sign of a deteriorating environment, at least in terms of aesthetics. LITERATURE CITED BAILEY, R.M. 19S4. Distribution of the American cyp- rinid fish Hybognathus hankinsoni with comments on its original description. Copeia (41:289-290. BOYLE, R.H. 1968. Notes on fishes of the lower Hudson River. Underwater Naturalist 5(21:32-33, 40. BOYLE, R.H. 1969. The Hudson River. A natural and un natural history. W.W. Norton t Co., New York, 304 pp. . COLE, C.F. 1967. A study of the eastern johnny darter, Etheostoma olmstedi Storer (Teleostei, Percidae). Cnesapeake Sci. 6:25-51. GIBBS, R.H. 1963. Cyprinid fishes of the subgenus Cvprinilla of Notrools. The Notropis whipplei - analostanus - chloristius complex. Copeia (37:511 . GREELEY, J.R. 1937. Fishes of the area with anannota- ted list. IN: A Biological Survey of the Lower Hudson Watershed. Suppl. Ann. Rept. New York State Conservation Department, 26:45-103. SNELSON, F.J. 1968. Systematics of the Cyprinid fish Notropis amoenus, with comments on the subgenus Notropis. Copeia (4):776-802. F-10 HONS 010106 TABLE I: Taxonomic Distribution of the Hudson River Fish Fauna (induces some unpublished records) Family Petromyrontidae Carcharinidae P.ajidae Acipenseridae Anguiilidae Clupeidae Engraulidae Salmonidae Osmeridae Esocidae Umbriaae Catostomidae Cyprinidae Ictaluridae Percapsidae Cadiaae Ophidiidae Belonidae Cvprinocontidae Atherinidae Synanathidae Casterosteidae Percichthyidae Lutjanidae Centrarchidae Percidae Pomatonidae Rachyce.ntridae Carangidae Sciaeniaae Lsbridae Muoilidae Stromatidae Cottidae fcothidae Pleuronectidae Soleidae Tetraodontidae Number of Species ' . 2 1 1 2 1 5 1 8 1 3 2 5 28 0 1 4 1 1 3 5 2 4 3 1 13 7 1 1 3 4 1 1 1 2 3 1 1 1 . . . F-ll MONS 010107 APPENDIX G Hudson River Fish PCB Analysis 1979 and L990 Samples New York State Department of Environmental Conservation, unpublished data, Hudson River PCB analysis - 1979 and 1900 samples. Albany, New York. HONS OlGlOd U>C\T>0W SPECIES NUMRER ANALYZED HUDSON RIVER fCt ANALYSES - 1900 SAXTLES NO. OF ANALYSES AVERAGE LCKCTK (mm) LENCTH RANGE ' - , (--) AVERAGE WEIGHT . Ja}____ WEIGHT RAKCE (R) AVERAGE LIVID (1) LIP10 RANGE (Z) AVLKACE re* fpi***) re* 1 pen ra:n.i. ____<!->, Cuikll 1 Pou(;likplt ilcubutgli I'uuktklU Imlltii Point Tappan Zee 6* MikrtAit SimMiIi 7/30/00 20 Axrlctn ilud (A/29) JLaa 30 7 Aarl(in ih<l (S/13) l l^rgMwuEh Gate (S/23) 20 Yallov parch (5/23) 10 Clialn pickerel(5/23) 2 Walleye (S/23) 1 American ihad (S/9) Roe PvMpitlweecd (Age 1+) 9/6/00 29 7. 75 hMiUtn tkad (S/7) Roe Aerice<i eel (10/26) # 31 7 6 American eliad (S/0) Aoa 30 1 20 179 . iw* m 135 100*200 y> ; * 316 ` 459*565 3 : 527 . 506*54) 1 ' . ! 4*3 i" 20 321 . . 260*410 10 229 . 169-325 2 ,386 t 1 345*421 l 514 ' 29 3 25 31 3 6 i S19 517 463*559 449*547 * i 529 476*582 529 501*561 357 , 306-452 1632 1769 790 632 164 382 1710 1762 1786 27 1916 1937 110 1100*2120 1550*1920 230*1365 70-395 230*535 1160-2360 1560*1970 .. 1500*2490 1700*2490 70*100 30 516 443*500 ' 1006 1450-2480 3 : 525 490*546 1984 1690*2300 1.7 11.3 1.4 3.9 0.4 0.2 0.2 1.7 12.1 0.9 4.9 12.3 2.1 4.0 12.7 0.9 <0,1*12.0 2.64 5.4-17.4 1.79 l.3-1.4 < 0.42 -0.1-2.6 0.96 <1.08 0.1-0.5 <0.98 0.1*0.2 < 0.98 - 5.61 3.3-19.2 1.42 0.8*1.0 <0.32 3.2*6.2 <0. 30- 25.11 <0.52*4.04 < 0.34-<0.44 <0.30-3.10 < 0.30-4.02 < 0.41*1.53 0.61-3.ft? <0.32-<0.3$ 5.1-16.0 1.27 1.2-2.4 <0.30 0.9-11.3 9.07 <0. 54-3.49 <0. 30*<0.30 2.14-23.05 7.0*10.6 1.55 6.7*1.9 <0.30 < 0.52-3.94 <0.30-AMO X i </> o o LOOT ION above feeder Stillwater Albany/l'roy - HUDSON RIVER fCB ANALYSES - 1980 SAMPLES SfCCICS NUMBER AXALY2ED NO. OF ANALYSES Puapklattid (Age 1+) 9/9/60 Brewu lull heed 1/23/80 Yellow Perch 6/23/80 LergeoouCh Bate 6/23/80 Puw|ihlnseetl (Age 1+) 9/10/80 Coldflah 6/23/80 Brown Bullhead 7/29/80 PuNpklitaeed (Age 1+) 9/2/80 72 30 7 26 75 30 21 75 24 30 7 26 25 30 21 25 6' 4 fl,,. (5/25) 1 .1 Bluebeck herring (5/28) 40 White perch (3/28) 30 Walleye (5/28) 4 1 30 4 Northern pike (5/28) 2 2 AVERAGE LENGTH (wm) LENGTH BANGS (mm) ... 265 240-299 213 187-261 267 126-396 * ` , ' *" 247 220-289 233 178-335 Al'EKACE WEIGHT .is> WEIGHT RANGE <g) 18 - 235 155-335 134 90-220 400 35-990 19 306 170-469 226 110-600 26 AVERAGE Lmo (7.1 HMD RANGE (t) (pp) 3.9 3.3-4.6 <0.60 0.9 0.1 0.5 3.2 4.7 1.4 3.9 0.3-2.5 <0.1-0.1 0.1-2.6 l.t-4.5 12.34 <0.84 10.16 20.12 0.6-16.7 0.1-5.6 2.9-,5.4 72.62 2.09 16.74 <0.46- <0.fl7 3.50- 30.1 1 <0.33- MS 1.67- 66.78 14.NO- 21.4 11.47-267.61 <0.30- 3.86 12.66- 22.59 518 572 276 " 182 474 616 450-572 '- 230-312 161-236 355-605 335-696 1528 2390 m 110 1326 1630 790-2390 " 120-280 70-235 410-2640 1030-2230 6.2 1.0 S. 6 5.2 1.2 0.3 2.8-11.7 1.72 < 0.31 -1.6-13.2 1.81 16.71 0.5-2.2 6.22 0.1-0.6 2.28 < 0.85-3.99 * - 2.60-46.17 2.30-10.n l.OB-3.47 OTTOTO SNOW C-2 TTTOTO SNOW 1 il 1 HUDSON'RIVER PCB ANALYSES 1980 SAMPLES LOCATION SPECIES NUMBER AXALYZED .. to. or . AKALrSES AVERAGE LEBCTK LD*TH RASCE . (-->) Poughkeepsie Croton I't. (Verpltnck) Zee Bridge Striped best 17 5/9/80 Striked bs* ' 17 5/7/80 Striped bast 23 I/IA/IO (eonflocated) Striped best 4/14/90 5/8/80 30*. 30 , ` 27 ` 27 . 23 -30 30 541 . 510-741 . ' 444 488-903 i V 520 / > 448-721 : . 1 . 515 1 ' 342-578 .424-482 Gcori;>! UiiililnKCon Me l<l(jo Striped bass 4/30/80 3/13/BO 30 ' 30 ;> 30 , * 515 . 415-653 30 . 403-758 AVERACE VElCirf (r) UEICHT RAXCE (r) AVERACE LIPID a> LIPID RAXCE tt) AVERACE PCB (pp*0 2070 3443 1643 1242 1553 1500-4605 1430-9430 990-4890 * 9.2 5.9 5.4 480-2200 780-3140 3.2 3.1 0.5-18.9 1.5- 8.9 0.8-12.0 1.99 9.05 11.68 0.4- 7.3 0.4- 9.8 S. 59 6.37 1543 2032 720-3370 . 620-5660 3.0 3.8 0.1- 8.9 0.8-14.4 5.00 4.44 res ua::i.c <0.30-11.7*9 2.47-47.01 2.33-52. 12 <0.90-14.28 <0.99-41.(iU <0.41-19.79 1.82-12.59 C-3 * ?TTOTO SNOW r 9 LOCATION ' HUDSON IKH KB UALVIES - 1M0 SAHTUS j- ' NIMKEB ANALYZED NO. OF ANALYSES . AVERAGE LENCTH ' LENGTH RAXCE (> . (Ml) AVEJtAGI VEIC1IT <f) UKicirr RANGE (*) cni'CD U<tlitH|ton A-etlcn 1(7/24) Kristas Itu 40(Hithtt<i) L'n<uaiio lrid|i AcL.. ..1 (A/lt) si R. |iM!eiiabu(g tu iilc) Amt lent ! (6/16) 5 19 16 29 5 19 : u. 29 ' *79 *09-587 *66: 374 *21 396-800 199-343 236-820 i- : 244 247 138 195 1*0-440 120-430 20-330 40-590 AVOUCE LIPID (X) LIPtO RANGE (XI AVERAGE PCI <PP*> 11.9 2.7-16.7 8. IS 9.2 3.3 10.3 1.5-16.6 1.7-16.7 . 1.1-25.* 3.69 6. 76 7.13 f*B i . PCB RA.'fCE 2.43-12.7* <1.4810.24 <1.33-52.95 1.34-41.41 i C-4 r.OCATIcW 5 PIXIES Above Feeder Dm Puofklaseed (Ulum Fells) * Brown bullhead Stillwater PuopklnaceJ brown bullhead Waterford lloliawk R. 1/2 ml. Iron IliuitiOii R. below Lock 7 Largenouth bass Seutllnouth bass Blueback herring Aib.my/Troy fwepkinseed grown bullhead Alewlfo 0..(iklU KJn(ileu Aleuite Punpklnaeed Cruger Island Carp tfcO|>> Creek Alewlfo . KmtdouC Creek (near wulh) Rainbow snelt C.irp Alewlfe I'jufilikuopsls Atlantic toocod Ipfflsoit Rim fca akaltsis - 1979 collections . (ualese ethervlaa noted analytes were of Individuals on a standard fillet basis) , ..AVERAGE * ... ^AVERAGE AVERAGE NO, OP V LCKGTII 1; I.ENCTM RANGE ' WICIIT WEICIIT RAKCE LIPtO LIPIO RANGE FISK fns) (--) ft) <> (7.) (U M (17)* .. H . ' f, 76-113 3.2 2.2- 4.0 20 ' ' '308 64 (14)* 30 97 251 277-339 1 71-121 176-315 ! ; 441 223 295-600 ___ 50-370 0.4 0.1- 1.7 1.9 1.4- 2.4 0.8 0.1- 7.5 - r"rc 1 AVERAGE IXB * Ioimm) PCM RAnCK 'dmI <0.44 <0.36 19.91 6.97 <0.39-<0.67 < 0.30- 1.14 IS.63-25.4J < 0.83-59.79 30 4 .` 30 317 250-403 373' 349-394 * 276 ,, 256-307 494 900 . 180 f 200-960 667-1036 113-255 0.4 0.1- 1.4 2.4 2.1- 3.0 4.1 0.3- 7.0 4.60 4.68 2.33 < 0.55-18.15 3.34- 7.46 <0.60- 4.91 88 (22)* 22 18 112 292 273 f 1) 273 ` 23 (23)* 111 13 . 621 18 .290 25 : 5 24 134 566 287 13 164 86-135 ` 193-338 ` 245-315 . 2S0-290 364 w: 223 .237 96-J 30 : - 464-813 3417 270-310 s 281 110-170 356-705 253-313 '8 3136 268 137-222 . 34 65-653 165-379 . 180-345 -1644-6804 200-330 4-20 2551-4252 175-370 15-100 _ 1.8 0.7- 2.0 2.2 0.05-10.6 8.3 3.0-13.6 7.0 2.4- 15.1 4.3 2.4- 6.0 10.7 4.4- 18.0 5.8 2.1- 14.9 2.3 9.6 0.2 0.9- .6.0 7.6- 14.0 3.6- 12.8 0.6 0.3- 0.0 5.89 < 6.74 4.79 2.28 5.56 42.63 2.64 4.03 14.73 2.55 <0.67 2.46- 6.19 0.30-44.60 2.48- 7.91 0.63- 4.14 2.41- 7.99 11.95-127.10 <0.96- 6.99 1.37- 9.69 3.93-29.6) <0.54- 5.65 <0.35- 1.14 *N*bcr In parenthesis reflects number of ctepttltt onslysos on e whole body basis of yearling fleh. HONS 0 1 0 1 1 3 C-5  SPECIES . XO. OP risn NwwUvrgli Cornwall-onHodeon Foundry Cove PenkaUll Punpkinseed Rainbow aoelt Alawlfe Milta Cat flali 100 (23)* 16 20 2 01ue claw crab ilupatopencreea Huscle bluef tali 5 5 16 Yowklna Covt Carp I ll.ivirtraw Wy Niue claw crab . . Ilipiittpancriii Huscle Aclanclc toacod 7 7 13 Tappan Zee Bridge blue claw crab letact-no ahell Ifcpalopancreas Muscle 3 3 3 Tappan lea Sridga Striped baaa 3/29/79 11/20/79 AaetUan aliad 14 13 13 HUTSON RIVER PC ANALYSIS - 1979 COLLECTIONS AVERAGE LCSCTII - UMCTtl RAXCE r--> ra) AVERACE VtlCUT .ifij____ WEICIfT RANGE (a) U9 93-134 139 120-100 203 245-315 374 353-392 9 5-20 262 160-300 610 454-763 AVERACE lipid m mp(o range ttl 4.0 . 2.3 0.1 2.1- 4.0 0.5- 4.3 2.6-13.3 3.5 . 2.1- 5.0 AVERAGE Pgr rca uv:c: 'im*! 2.99 4.51 2.71 12.12 1.031.57<0.96- 4.IN 9.47 5.56 5.32- 1M.M 177 . 121-203 632 392-733 - --` 74 3063 -- 57-113 ` 022-4336 5.3 0.2 1.5 6 152 110-183 ^ . 25 10-60 456 ` ` 366 511 424-695 303-366 413-561 1070 601 1726 000-1269 341-2043 1195-2540 5.5 4.7 17.7 3.4- 7.6 0.1- 0.3 0.4- 3.3 3.0-14.0 9.64 <0.34 3.15 36.49 5.0O- 20.21 <0.30- <0.45 <0.65- 6.61 <0.73- 119.0 1.7- 4.6 0.2- 0.7 0.2- 7.0 4.62 <.0.69 < 0.37 2.70- 8.51 <0.30- <2.19 <0.30- < 0.57 1.6- 4.5 . 2.95 0.9- 7.7 6.73 0.2- 0.5 < 0.40 < 1.73- 5.S3 < 0.89- 16.9.' < 0.30- < 0,71 2.7- 9.2 2.3- 9.0 9.5-23.3 5.27 8.53 1.37 2.11- 10.71 <0.59- 27.11 0.37- 2.51 `Number la parenckeala reflecta aueibar of caapaiUi ualyiti oo a whelt body baale ot ywili| flak. HONS 0 1 0 1 1 4 C-6 LOCATION SPECtfS Catsklll Creek (So. Cairo) American col Noraaitekltl Creek (Ut. 146 A 443) Mooihia Crick (Valti Cote) Sawklll Crock (Anitidalc*oi>-Hniton) Sawwlll River (Yonkers) PCt ANALYSIS OF AMERICAN EEL FtOH HOPSON IIV^I TM161/TAR163 - 1979 COLLECTION . 4 NO. Of ' AVERAGE ' IENCT1I M . . LENGTH RANCE AVERAGE HEIGHT .1*1___ WElCIfT RANGE <r.\ AVERAGE LIH0 (2) LIPI0 RANGE (1) AVEMCE PCR pcr iu.'u:e 20 491 , A404-790 263 l 22 . . 4,5 ' 307-643 ^ ; 298 21 ' 374 216-469* 113 20 467 ' 246-633 226 20 434 . 267-546 . 170 114-1092 43-1121 <40-198 . 10-331 26-304 10.3 3.8 6.9 7.3 12.6 2.1-20.0 0.2- 9.66 1.2-16.6 0.4-26.9 0.6-22.2 <0.47 <0.30- <0.73 <0.73 <1.15 <0.30- 2.13 <0.40- 7.30 2.55 <0.69- 6.75 3.69 <0.60- 6.60 X o z (/) / o * o ,1 G-7 APPENDIX H Air Quality Data HONS 010116 TABLE H-l Glens Falla Annual Wind Frequency Distributions (in percents) Direction N NNE NE ENE E ESE SE SSE S ssw sw wsw w WNW NW NNW 1-3 5.72 3.63 2.19 1.32 0.32 0.68 1.64 2.76 4.50 2.71 1.40 1.27 1.47 1.89 3.26 5.53 Wind Velocity Mph 4-7 8-12 13-18 3.01 2.14 1 .94 0.64 0.33 0.42 0.98 2.71 a.43 5.21 1.61 1.55 1.43 0.99 1.27 1.92 0.67 0.85 1.21 0.22 0.02 0.00 0.17 0.85 3.98 0.73 0.40 1.41 1.24 0.98 0.45 0.45 0.00 0.20 0.11 0.02 0.00 0.00 0.09 0.02 0.43 0.05 0.09 0.17 0.16 0.22 0.00 0.08 19+ 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.11 0.00 0.00 0.00 0.00 0.00 O.QO 0.00 Total 9.40 6.82 5.45 2.32 1.25 1.10 2.88 6.45 17.34 8.70 3.50 4.40 4.30 4.08 4.98 7.98 Total 40.87 34.70 Mote:1. Calm 9.05Z. Source: NTSDEC, 1979. 13.63 1.64 0.11 90.95 H-l HOMS 010117 Table H-2 Remaelaer Annual Wind Frequency Distributions (in percents) Direction N NNE NE ENE E5 ESE SE SSE S ssw sw wsw w WNW NW NNW 1-3 1.59 1.62 0.98 0.88 1.89 2.20 2.18 2.43 5.24 3.78 2.15 1.25 1.80 1.40 1.59 1.15 4-7 Wind Velocity - MPH 8-12 13-18 1.50 1.99 0.96 0.27 0.47 2.83 1.82 1.46 4.22 2.60 1.30 1.18 1.95 2.08 3.77 2.37 0.42 0.57 0.20 0.08 0.14 2.04 1.44 0.99 3.94 0.97 0.38 1.44 0.94 1.68 4.31 2.01 0.13 0.20 0.10 0.06 0.06 0.19 0.22 0.51 2.06 0.24 0.09 0.71 0.33 0.90 4.05 1.13 19+ 0.00 0.04 0.03 0.00 0.00 0.04 0.00 0.09 0.10 0.00 0.01 0.10 0.03 0.24 1.46 0.10 local 3.64 4.42 2.27 1.29 2.56 7.30 5.66 5.48 15.56 7.59 3.93 4.68 5.05 6.30 15.18 6.76 Total 32.13 30.77 21.55 Note: 1. Calm 2.332. Source: NYSDEC, 1979. 10.98 2.24 97.67 H-2 M0NS oioaia APPENDIX I Recommended Guideline for PCB Levels In Air: New York Scate Department of Health Kim, Nancy K. (written communication). March 25, 1981. Letter from Nancy K. Kim, Director, Bureau of Toxic Substances Management, State of New York Department of Health, Albany, New York to Donald Corliss, New York State Department of Environmental Conservation, Region 5, Raybrook, New York. Hawley, John, (written conmunlcatlon). March 16, 1981'. Letter from John Hawley, Chief, Bureau of Toxic Substances Management, State of New York Department of Health, Albany, New York to Italo Carcich, Bureau of Water Research, New York Department of Environmental Conservation, Albany, New York. HONS 010119 'STATE- OF NEW YORK A . DEPARTMENT OF HEALTH OFFICE OF PUBLIC HEALTH TOWER BUILDING QAVIO A*CL00, M.l QUCNN c. HAUGHlC. . flrar.Nr THE GOVERNOR NELSON A. ROCKEFELLER EMPIRE STATE PLAZA ALBANY. N.Y. *2237 DIVISION OP ENVIRONMENTAL HEALTH ico j. hctunc. p.t.. Pn.o. Marth 25, 1981 Mr. Donald Corliss DEC - Region 5 Route 86 Raybrook, New York 12977 Dear Mr. Corliss: . *. Re: Application - Hudson River PCB Reclamation Project The attached letters of March 13th and March 16th from John Hawley of my staff to Italo Carclch constitute the Department of Health's response to your February lOeh request for comments on the above application. This Includes comments on the draft environmental Impact statement dated September 1980. 1 would like to amend one statement in the March 16th letter. The PCB reclamation program-activices should be designed and carried out In such a way as to insure that the 24 hour average (not 8 hour average) PCB concentrations in the ambient air at occupied residences and other sensitive receptors affected by the activities do not exceed one microgram per cubic meter (1 ug/m^). Sincerely, AAA NKK/pab Attachments Nancy tC. Kim, Ph.D. Director Bureau of Toxic Substances Management cc: Mr. Italo Carclch Steve Arella - EPA Dr. Heeling Mr. Smith Distribution: Mr. Decker - Northern Area (Albany Office) Mr. Rellley - Southern Area (White Plains Office) Mr. Buff - New York City Area Mr. Baldwin - Oneonta District Office , Mr. Fear - Glens Falls District Office Mr. Cunnan - Amsterdam District Office MQNS 010120 1-1 STATE OF NEW YORK *X,, . ' DEPARTMENT OF HEALTH tel OFFICE OF PUBLIC HEALTH TOWCN SUILOING e*VlO AHfLAOO. M.O. OLCMM e. H*UMIC. H.O. THE GOVERNOR NELSON A. ROCKEFELLER EMPIRE STATE PLAZA AC9ANV, N.V. 12237 DIVISION OF ENVIRONMENTAL HEALTH LEO i. HtTLIHC, r.c., PH.O. DlitiMf March 16, 1981 Mr. Italo Carcich Bureau of Water Research DEC 50 Volf Road Albany, New York 12233 - Dear Italo: . I would like to add to Che comment* in my letter of March 13th, on the Important topic of acceptable exposure to PCB 11 ambient air. PCB reclamation program activities r.hould, be designed and carried out In such a way as to Insure that eight hour average PCR concentrations In the ambient air at occupied residences and other sensitive receptors affected by the activities do not exceed one inicrogram per cubic meter (1 uj/m3). An essential consideration In anlvlng at this guideline was the limited duration of the reclamation project. Individuals will, he exposed to these elevated concentrations for only three or four months in two successive summers. If you have any further questions; I will l*o glad to assist In any way I can. Sincerely, i // i p uLiUJv-j Jo\\\j Hawley /J Bureau of Toxic Subs tanccs Management Jlt/pb cc: Don Corliss - DEC Steve Arella - EPA HONS 010U1 Ap 15 APPENDIX J Estimate of Maximum Probable PCB Flux to the Atmosphere from the Hudson River Sediment Disposal Basin DiToro, Dominic M. and Donald J. O'Connor, April 14, 1981. Estimate of maximum probable PCB flux to the atmosphere from the Hudson River sediment disposal basin. Unpublished report, HydroQual, Inc., Mahvah, New Jersey. J-l HONS 010122 I. SUMMARY AND CONCLUSIONS An analysis of Che maximum probable PCB flux Co che atmosphere from Che proposed Hudson River Sediment Disposal Basin has been made. In order thee an air quality standard of l ug/m^ not be exceeded, the air quality model calcu lations done by Malcolm Pirnie Engineers indicate that under critical conditions 2 the emission flux should not exceed 780 ug/m /hr. Similar model calculations 2 by UAPORA indicate a maximum flux rate of 500 ug/m /hr. This report addresses the probable highest emission flux to be encountered during the dredging opera tion. The volatilization mass transfer coefficient is estimated to be in the range of " 0.28 - 0.44 m/day (0.012 - 0.018 m/hr) during critical condi tions. The higher value is adopted for this analysis. An analysis of che behavior of the sedimentation basin indicates that the maximum dissolved PCB concentration to be encountered is the concentration which is in equilibrium with the influent sediment mixture. This is the case regardless of Che details of the sediment mixture properties, such ss particle size distribution, settling velocities for particle size classes, etc. For the critics! flux rate and volatilization mass transfer coefficients given above, the critical dissolved PCB concentrations are C * 43 ug/l (MPI) or 28 ug/1 (WAP0RA). If the critical dissolved concentration is exceeded during dredging operations, and Che critical meteorology occurs as well, then it is computed that the air quality standard at che nearest receptor of interest could be violated. The maximum probable dissolved PCB concentration has been estimated by relating, the sediment PCB concentration and the desorption partition coefficient to the percent volatile aolids in the sediment. Over the range of volatile solids percentages present in Hudson River sediment to be dredged, the upper limit of the observed sediment PCB concentration has been established. The variation of desorption partition coefficient as a function of volatile aolida percentage is less certain. The sparse data available indicates chat it is consistently higher than that which would exceed the critical dissolved concen tration of 40 ug/1 but the data are not definitive. In addition the observed J-2 HONS 010123 dissolved PCB concentration from elutriate testa and extrapolated settling testa exceeded 10 ug/1 in two of the nine cases for which data are available, but did not exceed 40 ug/1 in any of the cases. It it concluded that: a The critical dissolved concentration in the basin of 28 to 43 ug/l will rarely be exceeded during dredging. However if it is exceeded volatili zation can be controlled by adding additional adsorbent to the dredged material, reducing the equilibrium dissolved PCB concentration and, therefore, maintain the basin concentration below the critical value. Before these operational controls are required, additional desorption tests should be made to determine the likelihood of exceeding the criti cal dissolved concentration. e The description partition coefficient data is sparse, and although it indicates that Che critical concentration will not be exceeded, the quantity of data available cannot rule out the possibility. e The project may proceed, based on the analysis presented below. However, it is strongly recommended chat additional desorption data be obtained and a more definitive analysis be made. II. METHODOLOGY The methodology employed in making the estimates of the PCB flux to the atmosphere is based upon a mass balance of total PCB within the basin volume. Since the principle sink of PCB ia via sedimentation of the particulate frac tion, an analysis of Che sediment solids themselves is required. Let ar (og/l) be the concentration of sediment solids entering the basin at a flow rate, Q (cfs), the basin volume is V, the average depth is H, and the settling velocity of the solids is V^. It is assumed in this analysis that only one size class of solids is present. Subsequently the analysis is extended to multiple size classes. J-3 HONS 010124 The ness balance equation for solids states that: V dm * Qra. - Qm - v Am dt 1 3 (i) where A is the bottom interface area and m is the average solids concentration within the water column volume. This mass balance equation applies to a completely mixed volume. Spatial variation of solids concentration is addressed subsequently. At steady state, the solids concentration is given by: m. m IKt 8O where K v /H, is the apparent first order removal rate (day l) and t s$ o V/Q is the hydraulic detention time (day) of the basin. (2) The mass balance of PCB is complicated by the existence of two forms of the chemical: the dissolved concentration, and the particulate concentra tion, where these concentrations are expressed as micrograms of PCB per liter of solution volume. Three mechanisms are considered in this analysis: (1) adsorption and desorption; (2) sedimentation of the particulate form; and (3) volatilization of the dissolved form. The latter is the source of concern in this analysis. 1. Adsorption and Desorption The principal source of dissolved PCB in the storage basin is from the desorption of adsorbed PCB. Let be the rate of PCB desorption (ug/l/day) and let be the rate of PCB adsorption. The mass balance equations for dissolved and particulate PCB are: ------ - QCU. - QCj VR, + VR - K, AC, dt di d d a Ld V -drt-* - Q^C p.i - QC p + VRd + VRa - Vs AC p J-4 HONS 010X25 (3) where is Che aurface mass transfer coefficient for PCB (m/day). the analyaia ia to conaider the total PCB concentration. The key to CT_ - aC, +pC Adding Che mass balance equaciona yields: (4) dC dt QC-. - QC_ - K AC - V AC n T lq sp (5) where Che adsorption and desorption kinetic rates cancel. Since the maximum concentrations are of concern, a steady state analysis is appropriate. Consider an equilibrium between adsorption and desorption. Define the particulate PCB concentrations per unit solids concentration, r (ug PCB/g solids): r * Cp/m (6) It has been found that a linear isotherm is appropriate to describe the relation ship between particulate and dissolved PCB (see Figure 1, Horzempa and DiToro, 1981). r -7TCd (7) where is the partition coefficient (1/g). In fact different partition coeffi cients are found for adsorption and desorption with the latter being larger. Since the concern is with desorption, it is assumed that equation (7) applies for desorption. Consider the total concentration, c^, and express it in terms of C, and r. That is equation (4) becomes: d CT " Cd * mr and using Che isotherm .equation (7) yields: C, - C. (1 + mJO Td (9) J-5 HONS 010126 so chat Che ratio of dissolved Co total PCB, f, is: d 1 d CT l + my Similarly Che ratio of particulate to total PCS is: C 7r f . 1 - . _E , ------------ P dC 1 + my (10) (11) Since these fractions express the relationships between the dissolved and partic ulate concentrations and the total concentration, chey may be used in the total PCB mass balance equation (5) to yield: dCT V dT - <JCti - <*1 - Wt - VfpCT and at steady state: CT TTt o (fKp s fd.KL / H) (12) This aquation gives the total PCB concentration in the basin, C^, in terms of the influent total concentration, C ., the hydraulic detention time, t , and Tl O the removal rates due to sedimentation, and volatilization, K^/H, suit ably proportioned by the fraction of total PCB that is particulate, dissolved, f,. d f , and P The dissolved concentration in the basin, Cd,, is then: Cd - fdCT and the flux of PCB to the atmosphere, J, is: J - K Cj (13) (14) Hence the analysis requires an evaluation of equations (12), (13), and (14) with appropriate values for the coefficients. J-6 HONS 01012? III. SOLUTION The key Co a straight forward analysis of the basin concentration of PCS is to use the solids mass balance equation solution, equation (2), to evaluate the settling removal rate coefficient, K . From equation (2) it is clear that: K C - -i. - 1 so m Consider the denominator of equation (12): lMKo sf p + t o fd.KtL /H (15) (16) j t [-- - l) + t f K /H P \^m odL (17) -y K A /_L_Yl + l m\m " 'Ml + afjli (18) (a. - m\ - 1 *oKl/H 1 * u l * all * a jT - inTT t K, /H I_____________ o L 1 + m/T (19) (20) l + m.'J + c K /H _______l_______o L 1 m JT (21) Tti* algebraic steps r: substitute for K c , equation so f and f., equation (18), cross multiply by 1 m Pd simplify, equation (20) and (21). The result is: (17); substitute , equation (19), for and (l + mTp CTi CT T* M. t^/H (22) J-7 HONS 010128 Finally, the dissolved basin concentration, C is: d d 1 + mji 1 m.TT t K/H 1 oL (23) A further simplification is possible. Note that the dissolved concentration in the influent is: ai 1 + m.*7{ and the influent dissolved fraction, fd.x.,' is: 1 fdi 1 m.Tf (24) (25) which is eq (10) evaluated at the influent solids concentration, m. . expressions can be used to express the dissolved basin concentration terms of the dissolved influent concentrations, Cd.x.. The result is: These V in Cd " 1 + t f,.K,/H o di L <26) The remarkable simplification yields the following conclusion: the dissolved basin concentration, C , is the dissolved influent concentration, C , d di reduced by the loss due to volatilisation only. The dissolved basin concen tration does not increase due to desorption but rather decreases due to volatili zation. IV. EXPLANATION AND INTERPRETATIONS This result is somewhat surprising and requires an explanation. Consider the esse for which evaporation is an insignificant loss relative to the basin mass balance of total PCS. (It may still be important from an air quality point of view.) Then t o fd.Ki L /H << 1 and Cd * Cd.i.. That is, at steady3 state,* the dissolved basin concentration is the same as the influent dissolved con centre cion. Imagine the following situation: the basin contains initially only water and no suspended solids. Set Che initial condition of the water at the J-8 HONS 010129 influent concentration. This does not affect the final basin concentration sioee the initial condition washes out eventually and the steady state concentration is independent of the initial condition. Now begin the influent so that the parti cles begin to enter the basin. Since the dissolved basin concentration is at tha influent dissolved concentration the particles see the same concentration and do not desorb any chemical. This assumes that the influent is at desorption equili brium. This is addressed subseqently. Nov the particles settle out. Consider a singla particle settling from the water column to the sediment. The removal of this particle does not effect the dissolved concentration. Since the other particlea art unaware of its removal, they do not further desorb. Hence Che basin dissolved concentration remains at tha influent dissolved concentration. It is clear from this explanation why the basin dissolved concentration is independent of particle size effects and varying settling velocities. It does not matter what size particles settle first since they are in equilibrium with Che dissolved influent concentration. It also does not matter what the atate of contamination of the individual particles is, since they are all in equilibrium wieh the influent dissolved concentration and their selective removal by settling does not change the dissolved basin concentration, ao long as it is at the influent dissolved concentration. Hence the baain achieves the dissolved concen tration that is in equilibrium with the influent sediment mixture regardless of elective removal via sedimentation. The appendix demonstrates this result for particle specific settling velocities and partition coefficients. Hence the conclusion is that the basin dissolved concentration will achieve, as a maximum concentration, the dissolved concentration which is in equilibrium with the influent sediment mixture. The key to the analysis is, therefore, to make an estimate of the dissolved concentration which is in equilibrium with the various sediment mixtures likely to be present in the influent. In addition it is necessary to estimate the volatilization mass transfer coefficient, K^, and to review the air quality impact calculations. These latter two tasks are presented in the next sections. J-9 HONS 010130 V. VOLATILIZATION RATE OF PCB The rate at which PCB volatilizes from a basin is given by the product of the mass transfer coefficients, (ra/day), and the dissolved PCB concen tration, C^. The following analysis follows O'Connor, 1980, 1981. The two film theory of air-water mass transfer gives Che overall transfer coefficient in terms of Che liquid phase transfer coefficient, , and the gas phase transfer coefficient, K (O'Connor, 1980): g I_ L_ + *1 K1 * "g (27) where H is the Henry's constant of PCB. The importance of gas phase resistance depends upon the magnitude of the gas phase mass transfer coefficient, K , and 8 the Henry's constant: There is considerable uncertainty in the Henry's constant, which in dimen sionless units is: P_ MW H * 16 C T s (28) where P is the vapor pressure (mm Hg), is the aqueous solubility (mg/l), MW is the molecular weight and T is temperature (*K). Table 1 (Tofflemire and Shen) given below, lists the results: Solubility (ug/1) 240 80 340 TABLE l PCB 1242 Vapor Pressure (aim Hg) 4.1 x 10 7 9.0 x lo'? 3.0 x 10 Henry's Constant (20*0 0.024 0.16 0.013 J-10 MQN5 010131 At the critical windspeed of W - 1 m/sec, the gas transfer coefficient for water evaporation is - 200 m/day. For PCB a correction is needed for the de- creaaed diffusivity of Che larger molecule using the ratios of the molecular weight* to the 1/2 power yields. 53 m/day for PCB 1242. The factor HK , therefore, is in the range of HK 0.69 - 8.5 m/day. 8g For the liquid phase transfer coefficient, ) two regions of the basin are considered: the region near the basin influent where water velocities are high, and the remaining region where wind velocities determine Kj. The size of these regions are chosen to be 100 a x 100 m to be consistent with the air quality analysis. For the influent region, it is estimated that over the 10^ a2 region the average water velocity is 0.5 ft/sec (R. Thomas, Malcolm Pirnie, 1981 personal cosasunicat ion). The liquid film mass transfer coefficient is given by: (29) where is the molecular diffusivity of PCB, V is the velocity and H is the depth. A correlation to molecular weight (MW) is available to estimate the diffusivity of PCB: _ DL - 2.2 10 -2/3 (MW) * ~6 2 * 5.43 10 cm /sec (30) For s basin depth of H 10 ft in this region the resulting transfer coef ficient is: * 0.45 m/day (31) J-ll HONS 010132 For the other regions the water velocity is negligible and the wind velocity controls. The liquid phase controlled transfer coefficient is given by: K 1 (32) where is the drag coefficient, is the kinematic viscosity of water, W is the related speeds, wind velocity, to the viscous Cj 0.0016, p a/pw is sublayer ^ " 6* 2the ratio of air to water density and >L is fetch, and height of the waves. For low wind The kinematic viscosity is 2 * 0.01 cm /sec, P /P 0.0012 so that: aw * 0.46 ra/day (33) at a wind velocity of W 1 m/sec. Since both these transfer coefficients are essentially the same, a transfer coefficient of = 0.46 m/day is used for this analysis independent of location. The overaLl transfer coefficient, including both gas and liquid phase resistances is: 0.28 to 0.44 m/day (34) depending upon which gas phase transfer coefficient is used. conservative, the upper value of " 0.44 m/day is adopted. In order to be VI. FLUX RATE OF PCS AND AIR QUALITY IMPACT The flux rate of PC8 is given by: J * (ug/m2/hr) for C^. in ug/1. * 0.44 ra/day ' C,. (ug/1) <31 * 18.3 (ug/m2/hr) 3 J^O 1 1 day X 24 hr (35) J-12 HONS 010133 The air quality impact at the nearest receptor can be calculated from the analysis made by WAFORA. For the five cells (100 x 100 m) in an axis with the nearest receptor the air concentrations resulting from an emission rate of J J2 10 ug/m /hr are given in Table 2. CeLl No. 17 16 15 14 13 Total TABLE 2 Receptor Concentration . (ug/m ) 0.336 0.312 0.L98 0.252 0.168 1.27 An independent air quality assessment was made by Malcolm Pirnie Engineers. 2 For an amission rate of 158 ug/m /hr they compute a receptor air concentration of 0.2 ug/m3 . For J 10 3 ug/m2 /hr their reault wouLd be - 1.26 ug/m'* which is in close agreement with the WAPORA results. Therefore the nearest receptor air quality concentration, C ^ , is given by: ^air 1.27 (ug/m3) 103 (ug/m*/hr) x ^di (36) - 0.0232 Co,.i For an air quality standard of " 1 ug/m^ the dissolved influent concentra tion C,. must not exceed: di C^. max * 43 ug/1 (37) J-13 MOMS 010134 Hence the air quality standard at the closest receptor of interest is not ex ceeded if the equilibrium dissolved influent concentration does not exceed 0d..l 40 mg/1. next section. The factors that control the concentration are discussed in the VII. PROBABLE MAXIMUM DISSOLVED PCB CONCENTRATION IN THE BASIN INFLUENT It has been shown previously that the dissolved concentration in the basin reaches the influent equilibrium dissolved concentration at steady state. The volatilization and air quality analysis indicate that dissolved concentrations in excess of 40 ug/1 violate the standard for critical conditions. The problem is to estimate the highest probable dissolved influent concentration to be encountered in Che dredging program. This analysis is complicated by the vari ability of the sediment properties and degree of contamination. The approach taken in the analysis presented below is to index the sediment by the percent volatile solids it contains. The relationship between sediment PCB concentration and percent volatile solids is shown in Figure 2. The upper line on the figure represents the assumed upper bound of sediment PCB concentra tion to be encountered during the dredging operations. In order to estimate the equilibrium dissolved concentration as a function of percent volatile solids, the desorption partition coefficient is required. Some data are available which can be used to estimate the equilibrium dissolved concentrations to be expected. Elutriate experiments have been con ducted on various Hudson River sediment samples (Tofflemire, 1981). A four pert water to one part sediment mixture is equilibrated for one hour. Desorption experiments conducted at Manhattan College using Saginaw Bay sediments indicated that equilibrium is achieved in less than 15 minutes so that it is reasonable to assume that the elutriate tests are at equilibrium. The results are shown in Table 3 (Tofflemire, 1981). The unfiltered samples are included for completeness but are ignored in this analysis since it is not possible to estimate the dis solved concentration in the supernatant without an actual solids separation. J-14 HONS 010135 TABLE 3 EluEriaCe Test Data Locat ion Z Silt Z Volatile Solids Sediment PCB ug/g Dissolved PCB (ug/1) Partition Coefficient (1/g) 1. E. Channel Fc. 2. 3. Buoy 212-2L4 4. Lock 1 5. Albany Pore 6. Gt nuntown 7. Albany Turning Baa in <5 5.4 12 0.5 <4 75 (30% wood) 6 5-24 2.44 1.35 6.84 25.6 20.0 35 13 0.08 0.08 3.5 19.3 1.5 6.6 0.3 0.06 0.04 0.09 1.3 13.0 5.3 43.0 2.5 2.0 39 Unfiltered Samples Supernatant PCB (ug/1) C. 4 Bridga Bouy 202 Bouy 214 Mossetkill * Buoy 210 Thcapaon lal ii 2 1.5 < 11 65 20-60 17 20-60 44 6 2 -20 7 20-30 57.1 45.6 191 30-50 149 246 293 9.9 61.6 49 1 20 196 138 78 2.5 0.93 0.93 190 2 0.76 1.8 3.8 J-15 HONS 010136 The resulting partition coefficients versus percent volatile solids are shown in Figure 3. Saginaw Bay data are included to provide some additional information (Horzempa and DiToro, 1981). The line on the figure represents the partition coefficient which, together with the assumed upper bound of sediment PCB (Figure 2) achieves an equilibrium dissolved concentration of C.. * 40 di ug/l. Although the data are quite sparse, the observed partition coefficients are all in excess of the critical values represented by the line in Figure 2. However at the low volatile solids percentages (1 to 3% volatile solids) the observed partition coefficients are close to critical. It is clear that more data are required for a definitive analysis. Figure 4 presents the observed dissolved PCB concentration from the elutri ate tests (the circles) versus percent volatile solids. Extrapolated dissolved concentrstions from settling tests (the squares) are also presented. Note that two samples exceed 10 ug/l of dissolved PCB. This is uncomfortably close to the critical concentration of 40 ug/l. The conclusion from this analysis is that although it appears probable that Che critical concentration of 40 ug/l will not be exceeded with any regularity it ia possible that occassional higher concentrations may occur. Therefore miti gating measures should be investigated. In addition more systematic elutriate teat data, consistent with this analysis should be collected in order to rein force the conclusions drawn. VIII. CONTROL MEASURES The analysis presented in this report suggests that the controlling variable is the equilibrium dissolved concentration in the influent. Any method which reduces this concentration would reduce the air quality impact proportionally. Tha most direct method would be to introduce an additional adsorbent (e.g. fine clay or activated carbon) into the dredged sediment. This would increase the partition coefficient of the mixture of sediment and adsorbent and therefore reduce the resulting dissolved concentration. The details of the required quantities of adsorbent and the optimal location for its introduction can be addressed subsequently if the additional elutriate tests indicate that low partition coefficients and highly contaminated sediments occur simultaneously to any significant degree. J--16 HONS 010137 P a rtic u la te C o n c e n tra tio n , r , (n g /g ) Figure l J-17 HONS 01013d F.,5 - a. UBiii!wr VSrfSU* M Cohc*7.atioa, f"WC4yT UUATlLB P c6 C tu ceu t k a t h m S o i-.*j T j0 ViLATilS So4 IDS j-ia HONS 010139 F'l 3 Ds l*i* Tiis> r*AAT>T.0Kj ciff^icieAi- VE/esui Pf^re^r wotAtiLB :<uoj T3fsM cTi# m fu r ir m w t ff^ ic ie i J-19 KONS 010140 F'Y + bLUT.IATE TEST data THijet.U** fcB Vo CATtl. 6. Concentration) <. iS, VA/rsut f'e/rcevT J-20 MONS 010141 Appendix J.l Analysis Cor Particle Specific Settling Velocities and Partition Coefficient. I. Equations and Solutions. For an Influent sediment mixture of k*l,2,...,N classes of distinct particles let be the influent solids concentration* be the basin concentration, and Kgfc * Vfc/H be the apparent removal rate of particles of class k. Then at steady state: . mlk The mass balance equation for total PCB is: dt QC.Ti KLACd'k^1 K: , A C , sk pk Where C . is the partlculete concentration of PCB on the k P* For aach particle class, let particle class. <A2) Where w,k is the partition coefficient for the kth class. Then: CT ` Cd + "k rk (A3) or: N \\ (A4) M a + 21 -kV k" 1 (A5) so that: Cd 1 (A6) C t 1+fVk J-21 MONS 010142 The particulate fractions for each of the k classes Is: ,. pit CT ^ " CT . Vh . CT Cd . Vfc 1 +2-Vn n (A7) Where the denominator summing index is changed to n for clarity, Hence the total PCB concentration mass balance equation is: v 4r - * cTi -q CT - <S.A cd - A cpk (AO) ^CTl-(5CT-KLAfdCT- A CT i Ksk fpk and the steady-state solution is: CT . ____________________ ^Ti \1 + d VH + fpk Ksk> (A9) The denominator can be simplified as: -1 + <L k 1 + to (fd VH> + co f fpk Ksk Vk / *ik - *k v cokd I1 +2-Vn \ \ n H (A10) 1 ------ n1 + >m IT it n (Ail) i +2. * n + -2- lk k k 1 + 2_a i Vk + WH k (A12) J-22 HONS 010143 so chat the steady state solution is: (' 1+2- off) nn C T I +?... k ik + ta0Kdd./H (A14) The dissolved basin concentration is: Cd - fd CT l +5 n n Ti 1 +fVl + toKL/H k which can be expressed as: where: 1 + VdVH *tl di 1 +% "ik't (A15) CA16) (A17) is the dissolved influent concentration. Thus Che dissolved basin concentration Is the dissolved Influent concentration, reduced by the loss via volatization, and independent of the specific settling velocities, particulate concentrations, and partition coefficients of the classes of particles in the influent. J-23 HONS 010144 REFERENCES Ropp, R., 1979. Ph.d. Thesis. Columbia University, N.Y. Horzempa, L., DiToro, o. M., 1981. The Extent: of Reversibility of Polychlori nated Biphenyl Adsorption, Manhattan College, in press, Water Research. O'Connor, D. J., 1981. The Effect of Winds on the Mass Transfer Coefficient of Organic Chemicals. Manhattan College Progress Dept, to EPA Gulf Breeze Lab. O'Connor, D. J., 1980. Manhattan College Summer Institute Notes, Manhattan College, Bronx, N.Y. Pirnie, Malcolm, 1980. PCB Hot Spot Dredging Program Containment Site. State Dept. Eovir. Cons. For N.T. Toffleaire, I. J., 1981. Cone. PCB Volatilization. Memo, N.Y. State Dept. Envir. Tofflemire, T. J., Shan, T. T. Volatilization of PCB from Sediment and Water. Experimental and Field date, N.Y. State Dept. Envir. Cons. J-24 HONS 010145