Document v19j5Qj1r8VMj3ZrXEN6YneYw

ENVIRONMENTAL IMPACT STATEMENT ON THE HUDSON RIVER PCB RECLAMATION DEMONSTRATION PROJECT FINAL OCTOBER 1982 U.S. ENVIRONMENTAL PROTECTION AGENCY REGION II 26 FEDERAL PLAZA HONS 009505 NEW YORK. NEW YORK 10273 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION II 26 FEDERAL PLAZA NEW YORK. NEW YORK IOZ70 8 OCT 882 To All Interested Governnent Agencies and Public Groups: Ibis is to inform you that the final environmental inpact statonent (FEIS) for the Hudson River PCB Reclanation Demonstration Project is available for public review at the following locations: 1. Crandall Library city Park Glens Falls, New York 2. New York State Department of Bitfirotmental Conservation 21 South Putt Comers Road New Paltz, New York 3. New York State Department of Qivirormental Conservation 202 Mmsronedc Avenue White Plains, New York 4. Nov York State Department of Bivircemental Conservation 2 World Trade Center New York, New York 5. New York State Department of Bivixormantal Conservation 50 Wolf Road Albany, New York Ihis FEIS was prepared by the U.S. Ehviroranental Protection Agency, Region II. Die draft EIS (DEIS) was Issued on May 8, 1981, and a supplemental DEIS was published an August 28, 1981. This FEIS contains the following: o findings of the fined. EIS o responses to cements mode by federal, state, local and other interested parties on the supplemental DEIS o responses to EPA's independent "peer review" evaluation o the New Yack Stats Department of fhviromwntal Conservation's final EnvircrmentaL Monitoring Plan o the decision of the New York State Hazardous Haste Facility Siting Board (dated April 22, 1982) o Oaepenaation Plan for farmers adjacent to the proposed containment site. MQN5 009506 It is important to note that, while the FEIS identified and analyzed potentially significant inflects on the environment resulting from this.proposed project, this does not constitute EPA's final decision to fund this action. Section 116 of the Clean Niter Act requires the Adninistrator to make a nunber of determinations relative to the proposed project. These include: 1. Whether the project will demonstrate the feasibility of indefinite storage of toxic substances in secure landfills; 2. Whether the project will denonstrate an improvement of the rate of recovery of a national waterway; 3. Whether disposal of PCB-oontaminated dredged material in a secure landfill would provide a higher standard of protection of the public health, safety and welfare than disposal by other methods; and 4. Whether funds are available to the State of New York for the project under Sections 115 or 311 of the Clean water Act, or a ccnprehensive hazardous substances response and cleanup fund. While the FEIS addresses seme of these issues, the Administrator mist make the final determination. Cements oonceming the content of this FEIS my be submitted to EPA for consideration. All cements must be received within thirty (30) calendar days of the date of this FEIS. Please address your aments to the Chief, Environmental Impacts Branch, U.S. Environmental Protection Agency, Room 400, 26 Federal Plaza, New York, New York 10278. The Administrator's final determination will not be published until at least thirty days after the date of this FEIS. If you need any additional information, please contact Ms. Robin Rohn, EIS Project Officer, New York/Virgin Islands Section, Environmental Inpacta Branch, at (212) 264-8677. Sincerely yours, ional Adninistrator HONS 009507 executive suehaey DATE: TYPE OF STATWENT: October 1982 Final RESPONSIBLE FEDERAL AGENCY U.S. Environmental Protection Agency (ERA) Region II TYPE OF ACTION: Administrative BACKGROUND The final EIS identifies the full-scale dredging and upland containment project propoaed by the New York State Department of Environmental Conservation (NYSD0C) as the environmentally preferable alternative. Baaed on nunerous evaluations carried out by EPA and its environmental consultants, WAPORA, Inc., it was ooncluded that the full-scale dredging project would provide the greatest potential for demonstration of river recovery and indefinite storage of contaminated material in an environmentally acceptable manner. The final EIS also identifies the reducedscale dredging and upland containment project as an environmentally acceptable alternative. Although this reduced-scale project would also demonstrate indefinite storage of contaminated material in an environmentally acceptable manner, the potential for demonstrating an absolute improvement in the rate of recovery of the Hudson River would be less, relative to the full-scale project. A comparison of the full and reduced-scale projects is presented in Table S-l. A draft environmental inpact statement (EIS) was published on May 8, 1981, which presented the inpact assesanent of various project alternatives as well as recaamendstions to NYSDEC for the development of project modifications, monitoring prograas and contingency plans to ensure the protection of public health and environmental resources. These modifications, monitoring and contingency plana would be a critical element of the project and are consistent with the Congressional intent of section 116 of the Clean Meter Act (CHA). A monitoring and contingency plan has been submitted by NYSCGC and is included as Appendix A of this docuaent. In response to public comment and in the interest of the protection of public health, safety and welfare, NYSCGC has made provisions for financial assurances to farmers whose property adjoins the containment site and whose crops could potentially be contaminated as a result of the two year operation of the containment site during dredging. The details of these arrangements are presented in Appendices A and G of this report. HONS 009508 S-l Table S-l Ccsparlaon of Full-Scale and Reduced-Scale Projects Full-Scale Dredging all 40 hot spot areas in the river bed with containment in a secure site. Design and construction of a secure upland containment site capable of indefinite long-term isolation of contaminated material. Provision of secure cap and top dressing, and further bank stabilization if necessary, for the reenant deposits. Provision for containment of contaminated materials from three New York State Department of Transportation (NYSOCfT) dredge spoil sites (212, 13 and 204 Mutex). Provision for dredging and containment operational standards and procedures, mitigation measures, monitoring programs, ' and contingency plana necessary to safe guard public health and agricultural Reduced-Scale Reduction of the number of hot spots to be dredged to approximately 20 sites above Thcnpeon Island Da. Same, except for a reduction in capacity at the containment site. Same Same Same Provision for research studiea/environmental monitoring programs necessary to demonstrate the improvement in the rate of recovery of the river and storage of contaminated material. Same S-2 HONS 009509 PURPOSE OF FEDERAL EIS With the passage of section 116 of the CWA in October of 1980, Congress authorized EPA to make grants up to $20 million to New York State in order to carry out 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. Vie purpose of the EIS process is to identify and analyze any potentially significant impacts on the quality of the hunan environment resulting fran a proposed project. In addition, the EIS process provides the fonsi for soliciting public ocsments on a proposed project through a series of public meetings and hearings. A twenty-one member Citizens Advisory Caredttee (CAC) was formed to advise EPA on issues of public concern regarding the project. As stated in the NOI, the NEPA EIS evaluated the following: . no-action alternative . control of river flow . in-river detoxification . in-river containment . remnant deposit' alternatives in the area of the former Port Edward Dam . complete or partial dredging, combined with upland containment . dredge spoil disposal and treatment options . other alternatives concerning PCB removal, including alternative dredging and transport These alternatives were evaluated for potential beneficial and adverse, shortand long-term environmental iapacts under normal river flows, as well as floodflow conditions. Vie EIS analyzed the major primary and secondary impacts of the proposed projects on the following: A. Public Health 1. Protection of downstream water supply 2. Protection of gromdweter in the area of the oontaiiment site 3. Reduction of PCB volatilization from river bed and remnant deposits into the air 4. Reduction of containment site volatilization 5. Reduction of exposure through the ingestion of PCB contaminated food B. Fisheries 1. Permanent reopening of the ootmercial and recreational fisheries 2. Protection of endangered species (shortnosed sturgeon) 3. Reduction of the bioaccmulaticn of PCBs through the food web 4. Protection of wetlands S-3 MQNS 009510 C. Maintenance Dredging andNavigation _____ 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 River ccnmunities p. Agriculture Protection of livestock and their food sources through: 1. Reduction of river bed and remnant deposit volatilization 2. Reduction of oontairment site volatilization 3. Protection of groundwater in the area of the containment site E. Other Impacts 1. Evaluation of inpacts to future hydroelectric dam construction and usage FINDINGS OP THE NEPA FINAL EIS 1. Disposal of PCB-aontaminatad dredge spoils in a secure landfill should 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 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 either the full or reduced-scale project. However, it is important to note that the statutory provisions of section 116 of the CfA require the Administrator of EPA to render the final decision on the matter of the protection of public health, safety and welfare provided by the containnent site. This will be addressed once all public consent is received on the final EIS. 2. The proposed containment site, which now incorporates the modifications and design safe-guards dascribed in the draft EIS, should be environmentally acceptable for indefinite storage of PCB-contaminated sediments. The storage of contaminated sediments at the propomed containment site is not expected to causa significant long-term adverse effects on the surrounding oomunity. The approval of the ptopuaul containment site for disposal of PCB-contaminated sediment is not only contingent upon the determination by the Administrator of EPA that the proposed landfill meets the test of public health, safety and welfare provided by section 116, but also ipcn the Regional Administrator issuing a permit under the Tbxlc Substances Control Act. Such a permit, if issued, would require the Regional Administrator to grant a waiver of the requirement of 40 CFR 761.75(b)(3), regarding the fifty foot minimum requirement from the bottom of the landfill to the historical high water table. S-4 HONS 009511 Because the distance between the bottom of the landfill and the water table cannot be fifty feet or more in many areas east of the Mississippi River due to hydrogeologic conditions, EPA Regional Administrators have had to use the waiver provisions provided far in the regulations in order to approve PCB landfills. The rationale for the waiver include the fact that the use of state-of-the-art landfill design, leachate collection systems and monitoring programs did not present an unreasonable risk of injury to health on the environment from KB's. 3. The proposed dredging operation, which new incorporates the modifications and design safeguards reccnmended in the draft BIS, is not expected to have significant short or long-term adverse effects on the surrounding community, downstream water supplies or the ecology of the Hudson River. 4. Removal of PCB-laden sediments in the areas to be determined during the pie dredging monitoring program should demonstrate an improvement of the rate of recovery of the Hudson River under the full or reduced-scale project. 5. Removal of PCBs frem the upper Hudson River should also reduce the risk of: - the necessity to once again close the Hudson River fishery in the future due to high flows. (This assumes that the PCB levels in fish would drop to acceptable levels at acme time in the future without the project.) - conducting environmentally unsound maintenance dredging in the future - discontinuing maintenance dredging in the upper Hudson River due to the inability to provide adequate upland containment of PCB contaminated dredge spoil 6. The potential environmental risks associated with the no-action alternative could be greater than those associated with the full or reduced-scale alternative. 7. The reduction in average PCB sediment concentrations in Hew York Harbor due to ronoval of PCBs from the upper Hudson River is expected to be relatively snail. However, under satreme flooding conditions the action alternative may have acme beneficial impact on the harbor area. Also, in areas of rapid deposition in the upper estuary (such as the Albany Turning Basin) where routine maintenance dredging is conducted by the u.S. Any Corps of Engineers, the action alternative may also have a beneficial impact. 8. As presently proposed by NYSDGC, PCB volatilization caused by the discharge of contaminated dredged sediment into the containment site aould exceed the Hew Yack State Department of Health (NYSDCH) recommended 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 presented in Appendix J of the EIS shews that, with the mitigation measures presented in Appendix A of the final DEIS, the 1 microgram per cubic meter (ug/cu m) aabient air guideline should not be exceeded. S-5 HONS 009512 HISTORY AND O/EWIEW OF THE EXISTING PROBLEM Polychlorinated biphenyl* are a class of chemical ccnpounds 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 adhesives. During a thirty-year period ending in 1977, over 227,000 kilograms (kg) (500,000 pounds [lbs]) of FCBs were discharged into the Hudson River from two General Electric (GE) capacitor manufacturing plants at Port Edward and Hudson Falls, New York. Much of the discharged PCBs was absorbed by the bottom sediments of the river and acctstulated behind the Fort Edward cam. When the dam was removed in 1973 due to its deteriorating condition, a large amount of the PCBcontaainated sediments was released and migrated downstream. The downstream migration was further accelerated during flood situations, causing PCBs to concentrate in river bottcm sediments downstream from Fort Edward. project OBmapmn by nysdec As part of a court settlement between NYSDEC and GE, approximately $3,000,000 was spent by NYSDEC to investigate the extent of PCB contamination in the Hudson River and develop methods to reduce and/or remove the threat of continued PCB contamination. forty PCB "hot spots* have been identified In the upper Hudson River, based on five years of scientific and engineering studies. "Hot spots" have been defined as sediments containing 50 mlurograms per gram (ug/g) (parts per million [ppmI) or more of PCBs. PCB concentrations along the depoeitional shore range from 5 to 1,000 ug/g (ppa) in fine grained sediments. In addition, five PCBcontaminated remnant deposit sites have been identified. Ramiant deposits were formed as a result of the removal of the Fort Edward Dam, which caused water levels of the river behind the dam to drop significantly. This caused oncesutmszgsd bottcm sediments to be exposed to the atmosphere. At present, PCB concentrations in the reanant deposits range from 50 to 200 ug/g (ppm). The investigations conducted by NYSDEC .resulted in a proposal to dredge FCB-oontamlnated sediments frtm the upper Hudson River and deposit those sediments in a secure inland containment site. The environmental analysis, ousts, engineering, and feasibility of the project pcoroecd by NYSDEC are presented in a draft EIS prepared in accordance with the State fovlroramntal Quality Review Act (SSQRA). The full-scale project reocnsended in the draft SB3RA EIS was estimated to aost $40,000,000. Subsequent to the draft SBQRA EIS and In response to Congressional action described below, nysdec rescqped the originally proposed project to accomodate S-*6 MONS 009513 the $20,000,000 funding authorized by the amendments to the (OA) [Sections 116(a) and (b)] and state matching funds. The reduced-scale project, as developed by NYSD6C, would cost $26,700,000. CONGRESSIONAL ACTION In September 1980, Congress passed an amendnent to the CWA under Title I, sec tions 116(a) and (b), entitled the Hudson River rac Reclamation Danonetration Project. Funds for this project have been authorized under Title II, section 205(a), of the Act. Under this legislation EPA is authorized to expend up to $20,000,000 towards a proposed demonstration/reclamation project far removing and disposing of FCB-oontaminated sediments from the Hudson River. Section 116(a). The Administrator is authorized to enter into contracts and other agreements with the State of New York to carry out a project to demonstrate methods for the selective 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 the purpose of determining the feasibility of indefinite storage in secure landfills of toxic substances and of ascertaining the lnprtwement 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 the pollutants in such landfill would provide a higher standard of protection of the public health, safety, and welfare than disposal of such pollutants by any other method including, but not limited to, incineration or a chonical destruc tion process. (b). The Adninistrator is authorized to make grants to the State of New York to carry out this section from finds allotted to such State under Section 205(a) at this Act, except the the amount of any such grant shall be equal to 75 per centum of the cost of the project and such grant shall be made an condition that non-federal sources provide the remainder of the ooat of euch project. The authority of this section shall be available until September 1983. Funds allotted to the State of New York under Section 205(a) shall be available under this subsection only to the extent that funds are not available, as determined by the Adsinistrator, to the State of New York for the work authorised by this section under Section 115 or 311 of this Act or a comprehensive hazardous substance response and cleanup fund. Any funds used inrier the authority of this subsection shall be deducted fras any estimate S--7 MONS 009514 of the needs of the State of New York prepared under section 516(b) of this Act. The Adninistrator may not obligate or expend more than $20,000,000 to carry out this Section. The overall goal of the Congressional authorization is to allocate funding to assist in the cleanup of the PCBs in the upper Hudson River. The specific purpose of the authorization is to demonstrate the inprovenent of the rate of recovery of a toxic contaminated national waterway by: . selective removal of PCB-oontaminated sediments frcm the Hudson River . treating the contaminated sediments as required and burying those sediments in a secure landfill . development of monitoring and scientific studies for water quality arel fish, and monitoring the landfill site The legislation also states that prior to placing any contaminated materials in a secure landfill the Administrator of EPA must first determine that the placement of the pollutants in a secure landfill would provide a higher degree of protection of public health, safety, and welfare than disposal by any other methods including but not limited to Incineration or a chemical destruction process. In addition, before funding under section 116 of the CHA can be provided, the Administrator of EPA must determine that funding is not available under section 115 and 311 of the CM, as well as any- existing comprehensive hazardous substance response and clean-up fund. M3QIFICATICNS The modifications to the original project, as veil as to the reduced-scale project referenced above, include changes in the design, operational standards, contingencies, and long-term monitoring mid maintenance programs. These recamandationa are aonalatent with the Congressional Intent of section 116 of the CHA. The purpose of these modifications Is to provide the higher standard of protection for public health, safety, and welfare during dredging and disposal operations and throughout the life of the containment site. Short-term funding for up to five years would be allocated through federal sources to monitor and demonstrate improvement in the rate of recovery of the Hudson River and storage of PCB contaminated sediment in a secure landfill. The long-term funding for monitoring and operation and maintenance of the containment site would be borne by New York State. cmzb) nwoivagwr It Is recommended that. Instead of a separate Citizen Advisory Committee (CAC) and Settlmesnt Advisory committee (SAC) continuing through the operational phase of the project, a joint committee be formed. It la reooemendad that three member'a of the CAC, each representing different geographic areas along the Hudson River (upper, mid and lower), be selected to serve on the SAC. This joint ujnaittee would ssrve as the focal point for the distribution of project information and data while providing oversight and liaison between the affected oenmmities and the operational and regulatory agencies. S-8 HONS 009515 QiAFTER 1 2 3 4 5 table or ognitnes TITIE Executive Summary Table o Contents IOTIODOCTXCN PAGE S-l i Summary of Public Hearings Hudson Falls Public Hearing Poughkeepsie Public Hearing New York City Public Hearing l-i 1-2 1-2 1-3 RESPONSES TO OOHNBFTS 2-1 FEDERAL, STATE, LOCAL, AND OTHER SOURCES FROM MUCH OOMOFTS HERE RECEIVED ON THE CRAFT ENVIRONMENTAL IACT STATEMENT 3-1 FEDERAL, STATE, LOCAL, AND OTHER SOURCES FROM WHICH OMENIS HA/E BEEN RECEIVED ON THE SUPPLQENTAL DEIS 4-1 RESPONSES TO THE PEER RB/IEH B/ALUATION S-l ABBREVIATIONS USB) 6-1 CORRESPONDING ENGLISH AND METRIC UNITS 7-1 LIST OF PREPARERS S-l APPENDICES Appendix A - Final Qwironmental Monitoring Plan Appendix B - NYSCEC Proposed Predredging Plan Appendix C - Letter Fran NYS Solicitor General Appendix D - Cultural Resources Sunnary Appendix E - Ccaaent Letters Received on the Supplemental DEIS Appendix F - NYS Hazardous (taste Facility Siting Board Decision Appendix G - Condensation Plan for Farmers A-i B-l c-1 0-1 E-l F-l G-l HONS 009516 1 CHAPTER 1 nnuxucncN A draft environmental inpact statement (DEIS) for the Hudson River PCB Reclamation Demonstration Project was published on day 8, 1981. After a forty-five (45) day public review period, three public hearings were held, on August 28, 1981, a suppleasmtal DEIS was published. This docueent contained modifications to the DBXS, responses to public ouemenLS received during the 45 day review period, and the New York State Department of Environmental Conservation's Response to the Executive Sub-tv which describes monitoring and contingency plans for the project. The purpose of this final environmental impact statement (FEIS) is to respond to ccaments received from the public concerning the supplemental DEIS issued on August 28, 1981, and to present final findings. The three (3) public hearings an the DEIS were held at the following locations and times. June 23, 1981, 7:00 Bt Washington County Courthouse Itoute 4 and Maple Road Hudson Falls, Hew York June 24, 1981, 7:00 HI Dutchess County Ccnmunity College Pendell (toed Poughkeepsie, New York June 25, 1981, 6:30 M Mein Hearing Ftacm, 44th Floor 2 World Trade Center New York, New York __ Public notice of these hearings was ssde through an Environmental Protection Agency (EM) notification and through news releases in local newspapers in Albany, Poughkeepsie, and New Yack. The meetings were oo-cheired by the EM and the Assy Corps of Engineers (OCE). Representatives of EM, the COE, and MAPORA, Inc., participated in the presentation and were available bo answer questions and 1-1 MONS 009517 The EPA and COE opened the hearings with a brief synopsis of the purpose of the hearing and format. HAFORA followed with a presentation of the key project Issues, findings of the DEIS, and reocmendations. Hie EPA invited all parties to make oensients during the hearing and to siitmit any additional written comments on the DEIS or COE permit to EPA prior to July 6, 1981. The following is a stannary of constants made at the public hearing or received after the public hearing during the 10 day oonment period. Responses to 11 iisanil i are contained in Chapter 3 of the supplemental DEIS, and a complete list of organiza tions and individuals from which ocsments were received is on pages 3-1 and 3-2. 1. HUDSON FALLS wmr.Tr heaptw:* * Most of the ocnmenta expressed at the Hudson Falls public hearing were in opposition to the proposed project. Verbal and written consents were sub mitted by local govemeent representatives, farmers and landowners with prop erty near the proposed containment site, and other concerned organizations and individuals. The Citizen-Environmentalists Against Sludge Encapsulation (CEASE, Inc.) expressed disapproval of the site and presented preliminary results of a poll they conducted of public opinion about the taupused Project. The PCS project Citizens Advisory Casaittee (CAC) presented cements and reoasnenJatlona, but had not yet taken a position for or against the project. The New York Farm Bureau and the Warren Washington County Fane Bureau expressed opposition to the project. The main araas of ooncem raised at the hearing weret * 'too little emphasis given to agriculture in the DEIS) * Potential reduction in property values, especially for farms, near the containment site) * Public health concerns about the dredging and containment operations; * Long-term stability of the oontaiiment site; * The need for detailed monitoring and contingency plana for the project; * feasibility of detoxification of dredge spoils instead of long-term contairment; and * Presence of trace contaminants such as heavy metals at the oontaiiment site. 2. FOUBKEEFSIB PUBLIC HEARING Almost all ocsments at the Poughkeepsie Public Hearing were in support of the project, although most approvals were expwaead with concerns and ...... mnla tiara for project modifications. Several major environmental groups gave con ditional approval of the project, including: * Sierra Club * Hudson River Fisherman's Association * Scenic Hudson * Clearwater, Inc. * National Audubon Society -- 1-2 HONS 009518 ttost of the cements and reoosmendations concerned the following subjects: * Preference for the full-scale project, but qualified approval for the reduced-scale project; * Safety of downstream drinking water supplies during and after dredging operations; * Need for identification and mitigation of any unknown sources of PCBs in the Upper Hudson Diver; * Need for detailed monitoring and contingency plans for the project; * Inportance of continued monitoring of fisheries; * Education of local people about potential hazards of eating contaminated fish; * Need for a team of experts to oversee all phases of the project; and * Urgency of implementing the project as soon as possible to avoid further dispersion of hot spots. 3. NEW TOW aiY PUBLIC HEARING Comments received at the New York City Public Hearing were in s^purt of the recomas nriart project, although most approvals were expressed with casnents and recommendations, the following organizations gave full or conditional approval: * The Port Authority of New York and New Jersey * New York City Department of Ports and Terminals * Save Our Port * international Union of Operating Engineers Local 251 * Seafarer's International Union * United New York and New Jersey Sandy Hook Pilots Association. The Natural Resources Defense Council, Inc., raised a variety of issues about PCB transport mechanisms in the Hudson Diver, wetland hot spots, monitoring, and other subjects they believed were not adequately addressed in the DEIS. Host ccanents and race--end atlone made by organizations and individuals at the hearing involved the following subjects:* * Concern about PCB contamination of New York Harbor sediments, and laplications for future maintenance dredging and ocean disposal of spoils; * Underestimation In DEIS of major benefits of the proposed project for New York Harbor; * Concern over the protection of drinking water supplies taken fiaa the Hudson River; * Need for detailed monitoring and contingency plans for the project; * Preference for the full-scale project, but qualified approval for the reduced-scale project; * Need to identify unknown sources of PCBs In the Upper Hudson River; and * Need to assess the stability of remnant deposits. 1-3 HONS 009519 CHAPTER 2 RESPONSES in cowans Comments wars received from a variety of govemnent agencies and other interested parties during the consent period for the supplemental DEIS. A list of these organizations and Individuals is given on page 4-1. Written consents were reviewed, and representative categories of these consents are addressed below. The contents addressed are divided into 4 main categories as follows! I. II. III. IV. Dredging Operations Monitoring and Contingency Plans PCB Containtent Site Other Contents I. DREDGING OPERATIONS ~ 1-1 Consent: The factual data indicate that current 'Hot Spots* are being buried in erosion sediments at a reasonably satisfactory rate, and that dredging may well provide nothing more than an artiflcally induced 'scouring* effect. Coffin, Poughkeepsie, New York . 1-2 Response: Consent: Recent aaspling by NYSDGC in June 1981 indicates that, although slightly dilute, the previously identified hot spots are still highly contaminated and continue to be characterized as hot spots. The mechanics of the dredging operations will be designed to minimize the impacts of scour and create no significant impact. under "The No-Action Alternative* presentation in Chapter 2, page 2-3, there is no reason given for the asstsption that 100 percent of the PCB load at Troy enters New York Harbor...* The fact that PCBs settle in the Troy turning basin negates this. Also, what evidence exists for increasing PCB concen tration in the turning basin? If that were true, why not dredge there, as would otherwise be necessary, and properly dispose of that material which would have to be dredged any way? National Oceanic and Atmospheric Adninistration office of Marine Pollution Assesasant, Stony Brook, New York MONS 009520 2-1 Response: The statement referenced in the EIS is preceded by an "if" and is used only to calculate the worst case condition and resulting average PCS sediment concentration in New York Harbor, even though inprobable. Interpreting the results of a 1979 study by Bopp, page 2-3 of the DEIS states that, "...a maxlraun of 31 percent of the PCB load at Troy enters the New York Harbor." Losses upstream of the harbor occur due to volatilization, deposition in coves and broad shallow areas, and deposition in dredged areas such as the Albany Turning Baain. Evidence of this fact is documented by 1980 dredging activities by the (J.S. Any Corps of Biglneers in the Albany Turning Basin. Sediment PCB concentrations ranged from 7 to 48,000 ug/tag (ppb) with highest concentrations in the top 100 inches. This basin is dredged by the Army Corps of Engineers approx imately every five years to maintain channel depth and sedi ments are disposed in upland contalrment sites. It Is extxmaely unlikely that all of the PCB released from the Upper Hudson River is trapped in the Albany Turning Basin. -3 Gonsent: In Chapter 2, "The No-Action Alternative" section does not indicate how much of the routine channel maintenance dredg ing would be at the hot spots -- if any. Also, there is confusion as regards the volatilization matter in that the amount volatilized before dredging is not ccmpared to that trtiich would exist if hot-spot dredging were to occur. The prime question to address is really the concentrations of PCBa in sediments and their changes over time with or'with out mam action. __ _____ _ National Oceanic and Atmospheric Adninistration, Office of Marine Pollution Aeseaaaent, Stony Brook, New York. Response: - ftost of the PCB hot spots are located in quiescent areas along the river. Routine maintenance dredging takes place outside of these areas in the deeper channel area of the river. Routine maintenance dredging would remove only a small portion of contaminated sediment which has been scoured fzoa hot spots by high flows or river traffic. The DEIS estimates that, under normal flow conditions, routine maintenance dredging of 1,100 kg/yr (2,500 lb/yr) of PCB and a volatilization rate of 680 kg/yr (1,500 lb/yr) of PCB would eliminate the PCB load at 1Toy by the year 2013. The volatilization rate after hot spot removal is estimated on page 2-14 and 2-15 to be 375 kg/yr (825 lb/yr) under the full-scale alternative and 680 kg/yr (1500 lb/yr) under the reduced-scale alternative. 2-2 HONS 009521 The reduction of PCB load to Troy over tine for both the action and no-action alternatives has been estinated in the DEIS. Hcwever, this estimate cannot reflect or predict yearly fluctuations of river discharges and variations in the mees of PCB transported. (See pages 2-4, 2-14, 2-15.) 1-4 Cement: On page Ar-58 there is a list of four conclusions frae experience with dredging in the Hudson River. The fourth conclusion is "The worst case condition is likely at a low flow.* Two interpretations are possible: the rate of loea of dredged material is greatest at low flow; or the concentration of PCBs in the water ianediately downstream of tha dredge is greatest at low flow. The first inter pretation would not seem to be true but the second would. However, there la also reason to consider that tha greatest rate of loss of dredged material is a "worst condition" rather than an increased concentration immediately dawn river frcsi the dredge. In any event, the meaning of the statement should be clarified. Kim, Director, Bureau of Tbxic Substances Management, New York State Department of Health, New York Response: The second interpretation is correct in that under low flew conditions dilution is minimized within the pluae inaedlately downstream of tha dredge and concentration will be highest in that area. It is not anticipated that losses of PCB mass will vary appreciably within a normal range of river flews. Under flood conditions, or water ooluan thresholds described in Appendix A, dredging will cease. 1--5 Gcranent: In order to minimize reauapension of sediments and down river transport, dredging will be limited to "periods of relatively stable flow* (A-23). Dredging will not be done under flood flew conditions at a threshold of 20,000 cfs. How woe this threshold determined? National Resources Defense Council, New York, New York Response: This threshold (20,000 cfs) is the observed flood flow for the Hudson River at Mechanicville, New York, at which signifi cant sediment reauapension occurs (see Figure 2-1 in the IBS). Similar thresholds will be selected for other reaches of the river project area. 2-3 HONS 009522 1-6 Goment: Response to our recjjest for close coordination with state and private dredgirq operation has not been adequately addressed. Vte are not proposing use of material fra* outside the project area. It should be noted that the CMC also recommended that a PCB management plan be developed (3--13). EEC should actively develop a plan to encourage both COT and private individuals/entities to schedule all operations in this part of the river concurrently with the DEC. This would serve to ensure maximum use of the contain ment area and minimize interference with monitoring efforts. This might entail informing all potential users of the dif ficulty Inherent in dealing with the problem an their own. Transfer of funds to CCC might result in sWntantial savings to the applicant while expanding the amount of FCBs safely moved. U.S. Arny Corps of Engineers, New York District, New York Response: it is our understanding that the New York State Department of Transportation (dot) is presently developing a plan for future maintenance dredging activities. Wien this is available, DEC will coordinate with COT and any other individuals/entities involved in river dredging on the scheduling of such activities. 1-7 Goment: The docunent does not state whether barge overflow will be allowed or not during cUamhell dredging of the hot spots. Our own experience indicates that allowing no barge overflow will reduce the inpacts of dredging. U.S. Army Corps of Bqineers, New York District, New Yack Response: There will be no barge overflow. All supernatant will be con tained within the barge and transported to the contairaaent site for treatment. 1-8 Qaonent: A docunent should be published that discusses the results of pm dredging studies and propane a modifications to the dredging plan based on the information that is uncovered. National Resources Defense Oouncil, New York City, New York Response: Such a report will be published by NYSDEC when the predxedging monitoring program is completed. II. HCMITORmC AMD OdmHGTOCY PIANS II-l ccament: The supplemental DEIS changes the statement on page 2-3 of the DEIS to reflect the new lower EFA water quality criteria fee PCBa in water. The statement as revised, how ever, appears to indicate that the USGS monitoring data at Poughkeepsie and Waterford indicate that PCB levels are below 0.079 nanograms/per liter (ng/1). A reference should be provided. In any event, if monitoring data is referred 2-4 HONS 009523 I1-2 to, the year of aaiple collection should be provided as well. The water quality criterion of 0.079 ng/1 for PCBs should not be used to judge drinking water quality. Hater quality criteria oonsider the ingestion of contaminated water and contaminated aquatic organises taken from the water body. Drinking water guidelines are for the ingestion of finished water. Kim, Director, Bureau of Toxic Substances Management, New York State Department of Health, New York Response: this correction was meant to reflect the new EM water quality criterion for PCBs only, not drinking water. The sentence should read, *...PCB levels below the maximal level of 1.0 micrograms per liter (ug/1) (ppb) established by NYSDOH and below the 0.16 ug/1 (pptr) level calculated to represent a lifetime cancer risk of one in a million (KPI, 1980d)." USGS monitoring data were gathered at Waterford and Pough keepsie until September 1979 for raw water. The levels referred to in the DEIS represent finished water at these locations. (See MPI, 1980d p. 2-7). Gomnent: On page 3-11 of the Supplemental Craft, in response to cement maber 11-14, it states that if dredgirg causes unexpectedly high contaminated concentrations at downriver drinking water intakes, contingency plans for protection of drinking water will be implemented for high levels of metals as well as for PCBs. On page A-22 the sampling procedures are provided. The action level for PCB contamination is mentioned in the EIS, but no value is given for any metal, tfe assume that the maxiaua contaminant levels in the State Sanitary Code will be used to determine if metal concentrations in the intake water are ao high that contingency steps should be taken. Kim, Director, Bureau of Toxic Substances Management, New York State Department of Health, New York Response: The New York State drinking water standards for metals will be used to determine If contingency measures for drinking water are necessary. HONS 009524 2-5 U-3 II-4 Consent: The DEIS should design a sampling program so that daily samples are taken upstream from Chelsea with sufficient tine for analysis to be ocmpleted before PCBs could reach the intake. Brugger, Assistant Commissioner, New York City Department of Environmental Protection, New York Response: A water supply monitoring program has been recommended by the New York State Department of Health specifically for that section of the Upper Hudson River where the dredging is to take place (see page A-22 of the supplemental DEIS). The monitoring program is designed so that if no significant impacts of dredging on river water quality in the vicinity of water intakes along the Upper Hudson River are detected, it is anticipated that there will be no impacts further downstream into the estuary. If significant impacts are detected there is provision to increase both the frequency and spatial extent of the monitoring program as well as to implement contingency plans to reduce the resuspension of contaminated sediment. In addition, no dredging will be conducted under flood flow conditions where excessive sediment transport can occur. Under this program, no impairment of Hudson River water quality in the area of the Chelsea pump station due to this project is anticipated. Ccnmenti The DEIS should analyze the impacts of long-range transport of PCBs under high flow conditions and determine what cut off (threshold) points are needed at the dredge sites to insure that PCBs will not enter drinking water supplies. Frequency of high-flow conditions and quantities of PCB transported at various flow rates within the 'high flow* range must be documented. Brugger, Assistant Commissioner, Department of Environmental Protection, New York Response: All dredging will be done at stable flow conditions. A threshold value of 20,000 cfs at Mechanicville, New York, has besn developed to prevent resuspensian and long-range trans port of PCB. Based on historical records, this floodflow occurs 4% of the time. Above 20,000 cfs dredging would be halted. The saspling program described on page A-22 of the supplemental DEIS will ensure that contamina tion of drinking water supplies downstream does not occur. Hater sasples will also be taken immediately downstream of the dredge. MONS 009525 2-6 11-5 II- Gosment: The water supply considerations only cover water simply and do not address effects on biota. In addition, there is no provision to curtail or alter the dredging project If unacceptable levels of PCBs are discovered. National Resources Defense Council, New York, New York Response: In the Monitoring and Contingency Plan there are provisions for monitoring fish and macroinvertabrates. The plans also contain multiple mitigation measures to be lflplemented should unacceptable levels of PCB occur either in the water or air. Gcmment: The major contributors of PCBs to the envirorment nay be hot spots, oold spots, remnant deposits or unknown sources. The project does not allow far the importance of any source except hot spots. It is essential that the contribution of the other sources be carefully evaluated before the dredging begins. National Resources Defense Council, New York, New York Response: The final determination regarding the exact locations of dredging sites will depend on the pre-dredging monitoring program. The originally proposed dredging program was developed to maximize the mass removal of PCB fra* the Upper Hudson River. However, this approach may not control or remove thoee contaminated areas which can potentially, release, or are now releasing, PCB to the environment. The objective of the pre-dredging monitoring, as described in Appendix B of this report, is to maximize the protection of pdolic health and environmental resources, the criteria to determine final dredge site selection are also discussed in Appendix B. This pee dredging monitoring program will be conducted con currently with containment site construction. It Is not . anticipated that modifications to the original 40 hot spot dredging program will significantly inpact contain ment site design or construction. MOWS 009526 2-7 11-7 - 11-8 11-9 Comient: Rode diking of hot spot 18 referenced on page A-6 is unacceptable. This rock diking would create a swaaplike breeding ground for mosquitoes and alter the river so as to make this area a non-productive backwater with no flow. Presently, we have blue herons, mallards, and black ducks trtiich nest in this area, as well as extensive plant life which would be endangered by this diking project. Karen Scelzi, Fort Edward, Hew York Response: Rock diking has been found to be unacceptable for both hot spot t8 and 135 due to the coats associated with long-term monitoring and maintenance of structured. integrity. The final determination of whether no action, full, or partial dredging will take place in these areas will be based on the results of the predredging sampling program as well as the criteria developed by NYSCGC for prioritizing areas to be dredged. Goaraent: It is still unclear where wetlands will be dredged in the reduced-scale or full-scale projects and whether wetland values nay preclude dredging of seme areas. According to the Wetlands Happing project description, *a small portion of scam of the wetlands adjacent bo deep water hot spots and subject to scour will be dredged.* The FEIS should contain a detailed description of these hot spots and the wetlands that will be dredged. National Resources Defense Council, New York, New York Response: Those wetlands susceptible to scour are heavily vegetated with emergent vascular plants which possess well developed root systems. In comparison to non-wetland hot spots, these areas are not subject to high scouring. EPA has determined that wetland hotspots should only be given con sideration for dredging if the predredging sampling program determines that desorption is greater in these areas than in non-wetland hotspots. Commnt: Although long-term monitoring will not be funded by the EM grant. It is essential that the state be required to conduct these studies as a condition of the EM grant. The FEIS should contain a description of the state's long term monitoring plans. Natural Resources Defense Council, New York, New York HONS 009527 2-8 11-10 11-11 11-12 Response: The state mist carry out the specifications of the plan of operation for the containment site and dredging operations according to the conditions of the Toxic Substance Control Act (TSCA) permit. Long-term monitoring is also a cequirenent of the TSCA permit. Content: There is much discussion on PCB uptake by plants, yet no method has been described for the disposal of the grass cuttings resulting from site maintenance. The primary reason for cutting the grass was to prevent its ingestion ty wild life. If such a potential hazard, it should be disposed of safely, at least until the monitoring program established its safety (if such a conclusion results). U.S. Army Corps of Engineers, New York District, New York. Response: PCB in grass clippings is extronely unlikely. Studies by Cornell University have shown that the primary method of plant uptake of PCBe is through the leaves and not the root system. PCB volatilization off of the containment site cap is expected to be virtually non-detectable. Comment: Thresholds for inplementing contingency actions have been added as requested. Though useful, many are too general, not pro viding enough specific data on how and when the plane would be initiated. U.S. Any Corps of Ehgineers, New York District, New York. Response: Ns have requested that EEC Include these thresholds In tha final monitoring and contingency package included in Appendix A of this report. Consent: In discussion of stapling frequencies at the contaiimmnt site, the statement "...saapled in accordance with the site permit (TSCA)," appears at a number of places yet there is no permit available to determine what the criteria are. Evaluation is therefore not possible. A copy of the permit should be included or the specifications incorporated into tbs document for ready availability. U.S. Any Corps of Ehgineers, New York District, New York. 2-9 HONS 009328 11-13 11-14 Response: Hie approval required under TSCA will be made prior to the final EPA record of decision. Construction-related requirements will be incorporated into the site construction contract specifications. Long-term monitoring requirements will be included in the record of decision. Consent: On page A-20 (of the supplemental DEIS) there is a dlscussioi of air sapling procedures that will be used at the dredge to determine whether workmen and residents along the shore may be adversely affected. According to the information provided, air sapling will only be performed for the initial 10 days of dredging. This should be modified to include monitoring of the first days when elevated temperature and low wind speed conditions are experienced, leading to a greater evaporation rate and a corresponding Increased likelihood of high PCB concentration. Limiting such sapling to the initial 10 days, particularly if they are in the Spring at the beginning of the dredging season, probably will not correspond to the likelihood for PCB exposure. Additional saapling should be conckjcted beyond the proposed total of 20 aasples at the dredge and the unloading site, to insure that samples are taken at both sites under conditions of maxixua volatiliza tion. Kim, Director, Bureau of Toxic Substances Management, New York State Department of Health, New York. Response: Hie suggestion of increased sanpling at the dredge beyond the initial 10 day intensive saapling program, as well as saapling at the unloading site, is considered in the final monitoring and contingency plan package. See page 1-7, Routine Monitoring, for details of sampling location and frequency. " Cosment: Air saapling at the unloading site will be performed only if saapling at the dredge indicates concentrations of 1 ug/m* or higher. It is assumed that PCB volatilization at the loading sits is ccaparable to that at the dredge site. However, the unloading site ia close to the encapsulation site which will have "an overwhelming influence* on the local air quality (A-21). In addition, the process of slurry formation may Increase voletilization. Therefore, it cannot be assuned that values at the unloading site will be below recomended standards if they meet these standards at the dredge. Sapling should be dons at the unloading site as well as at the dredge. National Resources Defense Council, New York City, New York 2-iO HONS 009529 11-15 11-16 Responsei Pages 1-5 and 1-7 of the Envirocmental Monitoring Progii Identify routine air stapling at both the oontaii--int aite and at the unloading area, if the twenty-four hour average PCB value la greater than 1.0 ug/m3, mitigation maaeuree will be iaplemented including increased sanpling, treatment of lagoons with a slurry of powdered activated carbon, and use of protective equipnent on workers. Garment: Cn pegs 3-20 of the supplemental EIS, the maxioua ambient air criterion for FCBs (1.0 ug/m3) is cited as a 'safety guideline set by NYSDCH for residential exposure.* This is an improper interpretation of the intent of the Health Department. This is not a safety guideline for residential exposure but rather a maximal value for the limited duration of the proposed project! it would not be acceptable for long term or continuing exposure of the public. Kim, Director, Bureau of Tbxic Substances Management, New York State Department of Health, New York. Response: The maximal ambient air criterion of 1 ug/m3 is noted to be only valid for the limited duration of the project. Gonment! The monitoring program described in Appendix A of the supplemental CEIS does not include a study to identify unknown sources of PCBs. National Resources Defense Council, New York City, New York. Response: The U.S. Geological Survey, under contract to New York Stats, conducted a survey during the sumaer of 1981 to determine the unknown source(s) of PCB in the upper Hudson River in the vicinity of remnant deposit areas. The results at the study indicate that higher PCB concentrations are found in the canal (east) than in the west channel (main river) and are the results of less dilution and limited lateral mixing rather than additional `seepage* fron remnant deposit areas. Other potential sources of PCS have not been identified. 2-11 HONS 009530 11-18 Conraent! A more Comal commitment Co contingency funding chan is presently stated in the supplemental Draft is required. The response that the state's self-insurer status should also be sufficient to cover any future claims of daaiage that the people may have Is unacceptable. Karen Scelzi, Fort Edward, New York Response: EPA has reviewed New York State's financial assurances proposed under the project monitoring and contingency plans. Under current New York State law, the Court of Claims Act $8, the state has waived its sovereign impunity from liability and has consented to be subject to suit in circimstances where a private individual or corporation would be subject to suit. Since the state will conduct the project and will atm and operate the landfill site, a person injured by negligent operation of the project would have cause for action against the state. EPA has requested and received an opinion from the New York State Attorney General's Office that this project, including the operation of the PCB landfill, would fall within the type of activities for which sovereign immunity has been waived (Appendix C). Therefore, the state will not be required to adopt unuaual procedures or otherwise create "new law" to make recovery against it less difficult. The New York State Department of Environmental Conservation has conplied with EPA's request to provide special financial assurances to protect those farmers surrounding the contain ment aits from economic loss because of the potential for crop contamination during the dredging operation. The aasurenots have been specified in correspondence from the Gasadssioner of the DBC and are included as Appendix G, Compensation. III. OafOUTOBfr SITE III-l Comment: Construction and operation of the containment site requires a cceplex array of federal and state permits and certifica tions. It is essential that the FEIS describe these procedures along with their respective timetables. In this way the public will be informed of the various controls an the design and operation of the oontainment facility. National Resources Defense Council, New York, New York 2-12 HONS 009531 111-2 Response: Die state and federal permits, certifications ,and approvals required far this project are described on page 1-18 of the DEIS. All state permits, and the certification of the Hazardous Waste Siting Board, were required prior to EBA issuance of a FEIS. The section 10 permit issued by the U.S. Army Corps of Engineers for dredging and the TSCA approval for the site must be issued before EPA approval can be given. Comprehensive specifications Cor site construction operation and dredging activity will be developed. These specifications will take into account the design requirements and other specifications included in the permits and approvals. Garment: The discussion of leachate discharge considers both shortand long-term discharges. These figures should be ocnparable to those for water quality effects of disposal: however, they differ significantly. In addition, they are not comparable to figures in the DEIS. The following table identifies these discrepancies: Water Discharge Average PCB Hass of PCB Million Gallons Concentrations Discharged 1)Leachate Discharge (DBE1S A-29) 55 6.3 ug/1 5 lbs. over 2 years 2)Disposal Water Quality (E6EIS A-26) -- 10-20 ug/1 2 Iba/day 3)(DEIS 2-42) 91 it is essential that this be clarified. National Besources Defense Council, New York, New York Response: The nunbers presented in each of the three categories listed, i.e., Leachate Discharge and Disposal water Quality in the SEQR DEIS and the raster presented on page 2-42 of DEIS, are in fact different because the pollutant source is different. Leachate discharge is the liquid discharged as a result of natural dewatering, after the site has been closed, for the reduced-scale project. Disposal water quality refers to the supernatant discharged during the dredging operation. The last category (#3) refers to liquid dewatered, after the site has been closed, for the full-scale project. III-3 Gomment Surface water quality considerations estimate a maximal monthly average PCB concentration of 20 ug/1. This will result in an average daily discharge of 2 lbs/day and a 20 percent increase over background levels in the water column. These values are 2-13 HONS 009532 inordinately high, especially when it is considered that the settlement required General Electric to reduce their average daily discharge to .0022 lbs/per day. No contingency plan exists to decrease the concentration or halt this effluent discharge if adverse effects are discovered. National Resources Defense Council, New York City, New York Response: Although the effluent FCB concentration is estimated at 20 ug/1, at a river flew of 3000 cfs in the vicinity of discharge, the resulting water column concentration downstream of the point of discharge is estimated to be ffcout 0.1 ug/1. This resulting water column concentration is about 20 percent over background levels, is short-term in duration and is not expected to create any adverse effects. If the effluent concentrations exceed the permit discharge limitations, polymer additions will be provided to reduce the level of PCB. This contingency plan is described on page A-27 of the supplemental draft EIS. IV. Other Comments IV-1 Garment: A citizens oversight committee comprised of both members of the TAC and CAC is essential. Although the TAC has the technical expertise, the local citizens are on-site and would have the ability to spot problems on a timely basis. Karen Scelzi, Fbrt Edward, New York Response: EPA has recomended that the current Citizens Advisory Gonmittee be disbanded once the firal project recommendations have been made. However, in order to assure that citizen oversight continue through the operational phase of the project, EPA recomer da that CAC representatives from three different geographical areas (upper, mid, and lower Hudson) be placed an the Settlement Advisory Camittee. This will assure continued citizen input and oversight of the project implementation. IV-2 Consent: I think it would be helpful if you would provide an exact breakdown of how the 26.7 million dollars will be allocated among the various components of the project. Specifically, hew much money will be expended for: 1) actual dredging of the "hot spots* 2) mitigation measures outlined in EIS 3) monitoring devices for water quality 4) monitoring devices for air quality 5) water quality protection devices for comunities which rely on the Hudson River as a source of drinking water 6) construction of the containment site 7) monitoring of the containment facility 8) future research O'Leary, Dept, of Ports and Terminals, New York 2-14 HONS 009533 Response) The breakdown of these expenditures for the reduced scale project for site construction in 1983 and dredging in 1984 are as follows: (All oosts in Thousand Dollars) Phase 1981 Site Construction and Acquisition Intermediate Cover Cover Costs Site Modifications After Closure nsmant Deposit Areas 3 & 5 Top Dressing and Fencing Included in hot spot program 1982 1983 4,510 242 1984 121 1,300 520 1985 Total 4,510 121 1,300 520 242 Material Rehandling Dredging* Contingencies Engineering Design Monitoring (Contractual) Field Engineering and Construction Administration Legal, Administrative and Program Operating Costs** 335 285 470 830 267 8,660 285 375 260 440 2,200 850 950 1,000 267 8,660 1,800 1,000 1,540 2,640 4,100 Tbtal project costs 26,700 * Sufficient funding for 20 hot spots. ** Includes the following) - Probing and sampling of river Isplamentatian of Environmental Monitoring Program - Staff Engineering Services - Project laboratories - Personnel and ESquipnent 2-15 HONS 009534 NW--33 IV-4 IV-5 Garment: The FEIS should include a copy of the site discharge permit and the TSCA approval and describe any monitoring that is required by these permits. National Resources Defense Council. New York City, New York Response: The state's State Pollution Elimination Discharge Evaluation System (SPECS) permit is on file with DEC. Gcmnent: The final Toxic Substance Control Act (TSCA) approval will be made after the final EIS is published and prior to the record of decision (ROD). Reference to the TSCA approval and any monitoring requirements will be made in the ROD. According to the EIS, the full scale and the reduced scale project will remove and confine approximately 40 to 49 percent and 30 to 35 percent, respectively, of the PCBe frcm the Hudson River project area. Me understand that while both of these alternatives are recamaended, selection of the full scale proj ect will depend upon additional State funding, what additional funding sources and legislative avenues are available to iaplement the full scale project if the State Is unable to make up the funding difference of $13,300,000? Lisella, Chief, Environmental Affairs Group Environmental Health Services Division, Center for Environmental Health, Atlanta, Georgia Response: At the present time there are no additional federal or state funds available to supplement the existing $20 million dollars which would be used to implement the reduced-scale project. Gosment: New chemical methods of PCB degradation are being amouicad every week. These methods should be examined and, as appropriate, tested to determine their applicability to the material In question. Even if initial costs are higher, the long-term costs may be lower because there would be no need for containment site monitoring. Bendlx. President, Bivironnental Research, Inc., San Francisco, CA. Response: The feasibility of various methods of PCB degradation is discussed in the EEIS. These methods are (1) not aost effective, (2) infeasible for use on PCB contaminated sediments, or (3) currently tested as a bench scale operation. 2-16 HONS 009535 IV-6 A process recently developed by the Franklin Research Center in Philadelphia ia currently being tested for its effectiveness in degrading PCB-contaninated sediments and reanant deposits from the Hudson River. However, this process is at present used on a bench scale and has not yet received EPA approval for use. If the process is approved before project ocaplstion, and if it can be utilized to detoxify wet PCB sediments in the containment site or reanant deposits, its use will certainly be considered at that time. An vaeesmaent would be done to evaluate the technical and economic feasibility of the process as well as associated environmental lnpacts. Ccmnent: 1. There is no indication that PCB concentrations at gauging stations (not at those paints where drinking water is drawn) are increasing with time. In fact, the data in Appendix A suggest a decrease with time. 2. The PCB concentrations at gauging stations are indicated at no higher than 0.687 ppb (sometime between 1976 and 1979), considerably below the maximal level of 1.0 ppb presently reconaended by tha New fork State Department of Health. 3. As Is Indicated In the DEIS, "FCBe can be removed from river water, leaving it suitable for drinking.* 4. Fran the DEIS, it appears that there is no drinking water problem, and even If there were, it could be taken care of. National Oceanic and Atmospheric Administration, office of Narine Pollution Assessment, Stony Brook, New York. Response: Since General Electric has halted the discharge of FCBs to tbs Hudson River, concentrations in the water oolutn downstream have decreased with time. This trend may continue during the present low flow cycle of the river. However, a recent report by the U.S. Geologic Survey indicates that the PCB levels in the water column Increase as a result of desorption during extreme low flows and scour during extreme high flows. As illustrated in Figure 2-1 of the draft EIS, PCB concentrations of up to Sppa are being recorded during high flows. Available water treatment data from Waterford show that PCB removal is highly variable and averages about SOt. Assisting tbs 50% removal rate, the NYSDCH 1.0 ppb PCB guidelines for drinking water oould be exceeded in finished water during high flows in the river. In the unlikely event they were exceeded, contingency plans would be lmploaented. 2-17 HONS 009536 JV-7 IV-8 IV-9 Comment: The DEIS still doesn't clarify the possible erroneous conclusion of assisting that the declining levels of PCB in fish associated with the relatively low flow during the past few years will continue. Cleaner deposits have covered PCB sediments and the fish have been equilibrating with the subsequent lower levels in the water, the hot spot areas still remain however, and the first good flood could easily mobilize them by stripping the still thin, clean, sediment oover thus malting them available to fish. U.S. Arny Corps of Engineers, New York District, New fork Response: On page 4-6 of the draft BIS, under the inpact discussions of the No-Action Alternative, the present situation of PCB con centration decline in fish correlating with low river flows is described. Hcmever, also described in the sane discussion is the probable reversal of this decline, if flood conditions occur, due to the scouring of contaminated areas which may be pres ently covered by a fine oover of "clean" sediment. Consent: the DEIS should docunent current PCB levels in New York Harbor sediment and quantitatively determine rates of transport to the harbor under varied flow conditions, the docunent can then more accurately address the project's inpacts on our ability to dis pose of dredge spoils in the ocean. Brugger, Assistant Camnissioner of Envirormentai Protection, New York City, New Yack Response: Current PCB levels in the New York Harbor sediments have been estimated by Haloolm Pimie, Inc., to be approximately 3 ug/g (pps). No model currently exists to quantitatively project PCB con centrations in the harbor under varying flow conditions. Gomnent: It is evident that short-duration high flows in the past have transported PCB-contaminated sediments. It is not evident that this will hold true for the hot spots. If it did, why are there still hot spots? Obviously, short-duration high flows had relatively little inpact previously on hot spot areas. National Oceanic and Atmospheric Antainistration, Office of Narine Pollution Asswsanent, Stony Brook, New York. Response: as illustrated in Figure 2-1 of the draft EIS, during high flows PCB levels have increased to 5ppi in the water colimn. The most probable source of imich of these elevated concentra tions is the material acuured frcm the "hot spots". However, before a final determination is made with regard to "hot apot* removal, a predredging sapling program will be conducted utilizing site selection criteria in addition to mass concen tration (see Appendix B). It is possible that there are scse areas now defined as "hot spots" which are stable even under extreme flood conditions and will not be dredged. 2-18 HONS 009537 N-10 N-U N-12 Gozment: Response: Conment: Response: Goment: Response: There la no convincing arguaent presented that the project will lower the level of PCB oontazination in sediments of the lower Hudson River. Therefore, there is no indication as to ho* (maintenance) dredging there could be impacted under the no-action alternative. National Oceanic and Atmospheric Adninistration, Office of Marine Pollution Assessment, stony Brook, New York. As stated under the Findings of the Executive Sunaary, the refection in average PCB sediment concentrations in the New York Harbor due to removal and in-place containaent of PCB frcm the upper Hudson is expected to be relatively mail. Maintenance dredged material in the lower river and New York Harbor will continue to be a problem under the no-action or the action alternative. It is stated that the "No-Action Alternative (Asauaing That Routine Channel taintenance Dredging will Be Halted)* will have greater negative impacts than the "No-Action Alternative (Asauaing That Routine Channel Maintenance Hill Continue)*. This is not substantiated to any sufficient degree. National Oceanic and Atmospheric, office of Marine dilution Asaeamnent, Stony Brook, New York. FCB-oontaadnated sediment is presently being rearmed frua the upper Hudson River by routine channel maintenance dredging. If this dredging is halted due to site unavailability or high coats associated with obtaining secure upland containment sites, FCBs will remain In the river and be available for release to the environment. The docuaent recommends that no action be taken at remnant areas 3 and S. However, on page 11-1 the Issue of huaan use of these areas is not resolved to the same degree as tbs PCB volatilization issue. The issue of human use should be more thoroughly investigated before no-actlon Is recuimended. U.S. Army Corps of Engineers, New York District, New York. Because reanant deposit sites 3 and 5 are sometimes used as a motor bike trail area and are In relatively close pronimity to a residential area, the draft EIS 11 u.--inis that these areas be capped and fenced to prevent volatili zation and access. Unless the pee-dredging monitoring program identifies the remnant sites as the "mystery source* contributing significant amounts of PCB to the river above Rogers Island, it has been determined that with capping and additional stabilization, these areas will not need to be removed. 2-19 HONS 00953a w-u Cement: Response: It Is essential that the remnant deposits be caretuily sonitored to determine their volatilization and PCB contribution to the river. Die PEIS should contain a clear description of the relative contribution of all the remnant deposits and the studies that are being done bo make these determinations. National Resources Defense Council, New York City, New York A study undertaken by the U.S. Geological Survey during the sunter of 1981 indicated that the remnant areas are not con tributing to further PCB contamination of the river. An on-going study by Dr. Buckley of Cornell University, which monitors the foliar uptake of PCB from volatilization at the remnant areas, indicates that average yearly levels of less than the 1 ug/m3 guideline are present on the ressiant areas. DBC will be requested to do further air sampling on these ramant deposits during the simmer months to determine "worst case" volatilization rates. 2-20 HONS 009539 CHAPTER 3 FEDERAL, STATE, LOCAL AND CITHER SOURCES FROM WHICH comoos MERE RECEIVED FOR TOE CRAFT VIRXMEKEAL IMPACT STATEMENT federal Agencies: U.S. Amy Corps of Engineers Department of Agriculture, Soil Conservation Service Department of Health and Hunan Services Environmental Protection Agency Fish and Wildlife Service United States Coast Guard United States House of Representatives: Honorable Gerald Solanon __ New York State Assembly: Honorable Joseph Ferris Honorable Joan Hague State and Local Agencies: City of Albany City of Poughkeepsie New York City Department of Ports and Terminals Now York Farm Bureau New York State Department of Envirormental Conservation New York State Department of Health New York State Department of Public Service Port Authority of New York and New Jersey State of New York Deportment of Agriculture and Markets Wbiieii Washington County Fans Bureau Citizens Groups: Citizens Advisory Cbssdttee to the Dutchess County Legislature Citlzen-Envlronsientallsts Against Sludge Bicspsulation Hudson River Clearwater Sloop, Inc. Hudson River Fishermen's Association International Union of Operating Engineers Local 251 National Audubon Society New York Tbwboat and Harbor Carrier's Association PCB Citizens Advisory Committee FCB Settlement Advisory Ccmaittee Save Our Port Seafarer's International union Sierra Club United New York and New Jersey Sandy Hook Pilots Association National Aasources Defense Council 3-1 MO NS 009540 Othersi Steven Allen Defable Brown Charlotte Burkhardt Edward coffin Gerry Cutie Henry De Groot Robert Eddy Leroy Esin Hudson Heights of Moreau, Inc. Irene Klesentowicz Lawler, ttotuaky and Shelly Engineers Guy Matthews Jermine Matthews Ellen Mulvaney George Mulvaney Karen Soelzi Ralph Shapot 3-2 HONS 009541 CHAPTER 4 FEDERAL, STATE, LOCAL AND OTHER SOURCES FROM WHICH ocnons (WE BEEN RECEIVED FOR THE SUPPLEMENTAL CRAFT ENVIROtKNTAL IMPACT STATEMENT Federal Agencies: U.S. Any Corps of Engineers Department of Health and Hunan Services National Oceanic and Atmospheric Administration Stats and Local Agencies: New Yack State Department of Health The City of New Yack, Department of Envirofinental Protection The City of New York, Department of Poets and Terminals Citizen Groups: National Resources Defense Council Others: Karan Scelzi Edward Coffin Bendix Bivircnamntal Research, Inc. 4-1 HONS 009542 CHAPTER S RESPONSES TO PEER REVIEW QUESTIONS BACKGROUND On December 28, 1981> the Administrator of EPA approved a peer review process of all ERA'S scientific, educational and informational materials to assure that they are baaed on the best scientific and technical evidence available. (EPA Agency Order 2200.4). Since environmental iiipact statements are attributable to EPA, they are subject to this peer review procedure. In oonpliance with this order, EPA selected technical experts who are familiar with the subject of this document and could fully analyse the data. The reviewers were also selected for their expertise in biological and groundwater research. PEER REVIEW TEAM UMBERS The peer reviewers for the Hudson River PCB Reclamation Demonstration Project and their affiliations are: Dr. Martha Sager Professor and Chairperson Department of Biology American university Dr. C. H. ward Professor and Chairman National Center for Groundwater Research Rice university Dr. Raymond Harbison Professor and Director Division of Interdisciplinary Tbxicology university of Arkansas for Medical Sciences Dr. Richard Hill Senior Science Advisor to the Assistant Administrator for Pesticides and Tbxics Substances Environmental Protection Agency HONS 009543 5-1 RESPONSES TO PEER REVIEW QUEgTICNS The following are reaponaea to the ocnaents raised by the peer review process. We have categorized the questions and ocnaents according to topic and provided answers to each. Some of the peer review acmnents supported the findings of the draft EIS; those comaents are not presented below. Cement tl "The local residents and their elected representatives are opposed to the project on both econcmic and environaental grounds. The project is not popular in the Upper Hudson River area." Response #1 We acknowledge, and have stated in the draft and supplemental DEIS, that many lonsj residents and their elected government officials are opposed to the project. How ever, we believe that all of the ccaments, questions, and concerns expressed by the local population have been adequately addressed by the NEPA process. Goment 12 "The geological studies done at the site to support the appropriateness of the site for PCB disposal are shaky at best. There is no reason why one should not know the location, extent, ate. of sand discontinuities in the subsurface clay. These studies should be completed before further project development." Response >2 The geological studies oonductad at the proposed containment site are completed. Based on these studies, we believe that there is sufficient information to support the adequacy of the site for disposal of PCB contaminated bottom sediments from the Hudson River. With respect to the apparent lack of information regarding the location of sand discontinuities, we refer to information submitted by the New York State Department of Bivixormental Conservation which includes the testimony submitted to the New York State Hazardous WSste Facility Siting Board by Steven Wislaneky, felcolm Pimie, Inc., consultants to the NYSDEC on the project) "The light clay deposits at Sits 10 are termed varved clays. Curing its deposi tion, the lake in which the clay was deposited went through a series of freeze and thaw cycles. During the period when the lake was frozen, velocities in the lake were reduced and fine grain material was deposited. During periods whan no ice was on the lake, velocities were higher and coarse grain material was depos itad. Ths majority of the material on Site 10 is of a slightly coarser nature than the clay. It is a silt deposit aid there are also some fine sands within these varves. These sand laneas store water and the permeability of the fine tend verves are approximately 1 or 2 orders of magnitude greater than the clay Itself. The light clay deposits were laid down in horizontal layers. Due to the defal cation or drying-out of the clay over the last 13,000 years, some deformation 5-2 MOWS 0095*4 of the horizontal position has been experienced. In general, all clays in the Hudson River Valley had the sane means of deposition. The varves are normally not continuous, nor do they rarely exceed a thickness of 1/8 inch.* Content 13 'if it is true (and there is nothing in the reports I reed that indicates to the contrary) that dredging of 20 to 30 'hot spots' will renove only 30% of the deposited PCB and will have little or no effect on downstream PCB concentrations now or in the future, and that dredging will only decrease the projected 'wash out* time for PCBs by five years, then I see little to be gained by the project.* Response #3 In responding to oonnent ntmber 3, we infer that the oommentors reference to 'dcMnstrean' is taken from a statement in the supplemental DEIS referring to New York Harbor. In our estimation, the removal of 30% of the PCB contaminated sediment would not hove a great iiRpact in reducing the average PCB sediment concentrations in the New York Harbor. This statement was included in the BIS because of statements made by New York Harbor representatives that this project would 'solve* the PCB problem that has created dredging and disposal problems for the harbor In the past. Although the project may in fact reduce the threat of PCB contamination of the harbor in the future, we believe that a less optimistic abroach la appropriate. More important is the fact that either the full or reduced scale project will remove PCB hot spots from that portion of the river where they pose a threat to the viability of future maintenance dredging for navigation and serve as a constant source of PCBs to the river in the future. The projection made regarding "washout* time is based on a ninber of assumptions. It assuess constant flows, constant volatilization rates and the continuation of navigational dredging (with additional upland disposal sites) over the next 20 to 30 year time period. It should also be realized that dredging removes PCBs from the river ecosystem whereas "washout* merely re-distributes them downstream. It is important to highlight that taking a cautious approach in projecting any benefits to an area over 200 miles downstream from the immediate project area such as New York Harbor should not undermine the potential benefits to be realized from the dredging program In the upper and lower reaches of the Hudson River. Ccement *4 *It appears that the oost-effectlveness of this project Is minimal or negative. The 'do nothing' alternative has not been fully explored, and the potential rlmisge claims may emceed the coat of the project." Studies relating the amount of PCBs removed to cost originally found the full-scale project to be the most cost-effective. However, the total funds made available for this project were $26.7 million. The NYSEEC therefore reecoped the project to identify the most beneficial and cost-effective project elments which could be aompleted for this mount of money. 5-3 HONS 009545 With respect to the monetary benefits of this project, Carl Parker, Chief, office of Freshwater Fisheries Boonomic Department, NYSDBC, has indicated that the ccanercial Hudson River finfiah fishery wee worth more than $1.7 million in 1980. Since 1976, ocsnsrcial fishermen have been restricted in the sale of Hudson River fish by bans imposed by DEC because of PCB contamination. Were it not for PCB contamination, the Hudson River ocaamrcial species such as striped bass wid Merican esi could yield many more thousands of dollars to the New York economy. The average reported ocsmercial catch for striped baas between 1965-1975 urn 46,000 pounds. At 1980 prices, the striped baas catch oculd reach a value of $250,000. Using the fHFS multiplier (National ferine Fisheries Service of the U.S. Department of Oommerce) of five, the actual value of the catch could be worth more than $1 million. The project has incorporated operational measures and extensive monitoring in an effort to mitigate any potential adverse effects. 'Damages* resulting from the iaplSMntatlon of this project have been estimated to be minimal. Technical assssmnnts of poaaihle groundwater contaaiination, surface water supply contamination and air contamination have shown these potential problems to be either virtually non-existent or controllahle with existing technology. Localized contamination of agricultural crops has been identified as a possible adverse short-term effect. Estimates of crop cash value in the buffer area are in the hundred thousand dollar range, and a ocspensaticn plan for local farmers has been proposed by the state to mitigate this, should it occur. Please refer to Appendix G of the final EI3 for details of the farmer compensation program. Ccaemnt 45 "I found no evidence that ary credible scientist/engineer was confident in predicting enhanced environmental quality as a result of the project, fe have many praising envirormmntal probXams and can ill afford to allocate our resources to projects with lew envlronaental benefit projections.' The purpose of the EIS process is to evaluate ary environmental iiqpacts that would result from the implementation of the project. The intent of the congressional legislation is to carry out a demonstration project designed to ascertain any improvement in the rate of recovery of the river resulting from the dredging program. This can only be determined fay monitoring the river before, during, and after the dredging program. TO the extant which engineers and scientists could accurately end confidently pre dict environaantal benefits, the following estimeticna were presented in the draft EIS and supporting studies prepared in conjunction with the project: * * Both of these estimates aaaune volatilization will continue. They do not reflect fluctuations in river discharge of PCB mass transported. 5-4 HONS 009546 * under the Cull scale alternative, the PCB supply above the Troy dasi would be exhausted twelve years sooner than the no-action alternative (assuring maintenance dredging continues even if no action is taken). * under the reduced-scale alternative, the PCB supply above the Troy dam would be exhausted five years sooner than the no-action alternative (assuaing mainte nance dredging continues even if no action is taken). * for additional potential project benefits see response No. 4 above. A major aspect of this project is demonstration of an ixprovanent in the rate of recovery of the river by using the information gathered from comprehensive monitoring. This information will allcw us to predict enhanced environmental quality for similar projects in the future. CCsnsnt >6 The 'demonstration' aspect of the project is highly dmbtful and is certainly not unique, we already know how to build 'standard' hazardous waste disposal sites." Response 16 The Hudson River PCB Reclamation Demonstration Project is unique due to its purpose and design. The project's purpose is to demonstrate that removal and isolation of the PCB-contaminated sediments are technically achievable, and to ascertain any Improvement in the rate of recovery of the river due to this action. The design of the project has been developed and refined through five years of scientific and engineering studies. The design will ensure both safe encapsulation of the PCB-oontaminatad sediments and dredging that will be carried out in an environmentally acceptable manner. The ooqarehenaive monitoring program will serve not only to protect public health, but also to provide a usable data base for any future actions. (Please refer to Appendix A of this document for the particulars of the monitoring program). Consent 17 "The Department of the Interior has classified the Hudson River north of Albany as a recreational river beceums of its ability to support aquatic life and provide tin public sector with vort fishing. Since the river is thus classified the river is presuaably recovering from PCB poisoning. The assuiption should be therefore that such recovery will continue If the river is left undisturbed." The Department of the Interior classification of the Hudson River as a recreational river pceceaded the identification of a PCB problem in the Hudson. Thus tbs pre sumption that the rivers is recovering frtm PCB poisoning has no direct correlation to a "recreational" classification. 5-5 HONS 009547 Ml aasesaaent of recent fish data indicates the persistence of certain KBs in the fish. Sufficient data are not available to project whether the decreasing KB concentrations in fish are a trend that will continue or if this is a tsaporary phenomenon caused fay several years of 1cm flaw in the river system. The no-action alternative guarantees that PCB will be available to the "river system* in the future. Removal of all of the PCB-contaminated sediments frcm the system guarantees their isolation frcm the riverine environment and ecological pathways (i.e., fish, water supply, waterfowl). Although total isolation fra the environment cannot be achieved within the environmental and financial constaints of the project, and every mechanise of KB transport and dispersion in the Hudson River environment is not clearly understood, the action alternative will reduce the inventory of PCB in the system. Caseent M "The removal of an estimated thirty to forty percent (30--40*) of KB's fra the Hudson River bottom at selected 'hot spots' will leave about 200,000 lbs. (again estimated) of the toxic chemical remaining in the river. These will have been sufficiently re-introduced into the water oolimn and would cause the saae kinds of damage to the ecological balance of the river as additional dumping should that amount of KB's be introduced.* Response 18 It spears that there is a misunderstanding as to the meaning of the removal percentages referenced in ooaaent 18. The estimated 33 to 47 percent of KBs that would be removed under the reduced and full scale project, respectively, represent the total percentage of KBs which will be removed frcm the identified "hot spots* in tha river end not the percentage of PCB contaminated sediments removed frcm each individual "hot spot*. The remaining S3 to 67 percent (approximately 200,000 lbe.) of contaminated material is dispersed throughout the river. Theoretically, by dredging 98t of each of the "hot spot* areas, the greatest amount of KBs would be removed with the least cost and envlrcnaental iapact, and tha opportunity for resuspension of renaming contaminated material would be minimal. The U.S. Any Corps of engineers Report 7-77-24, entitled "Aguatic Disposal Pield Investigations, Duwaaish waterway Disposal site, Puget Sound, Washington,* presents biological and chartcal data far animals, water and sediment samples which indicate that no permanent environmental degradation of the area resulted frcm the dredging activity. Extensive dredging operations (1977) by the Deportment of Transportation at Itogers Island in Port Bfcsrd were monitored and no significant PCB transport was noted within a mils downstream. These results are docunented and published in Paper 165 by the New York State Department of Environmental Conservation, April 1981. HONS 009548 5-6 Gcaeent #9 Measurements of toxic response dosages of micro-organians to PCB's are nsilrmsi 11 j measured in micrograme per grzea of Body weight; measurements of toxics in water use micragrams per liter of Meter. The amounts of PCB's which will be re-introduced during the dredging will increase biotic systems exposures for food chain organises through contact and ingestion. Whan micrograms are oospared amounts measured in thousands of pounds, a staggering ntmber of microgram, contacts result. These lumbers of exposures of Biotas Systems will not occur: the recovering ecosystem will not suffer such stress If the dredging project Is not activated.* Response 9 See response to consent No. 8 Consent >10 "The statement was made in the EIS that the proposed dredging activity would provide potential for the re-developaent of a former fisheries industry. The upper reaches of the Hudson River maintains one of the largest striped bass spawning grounds in the aaat ooaat. It also supports herring, sturgeon, and Shad. Striped Baas eggs and fry are particularly susceptible to toxic chemicals, fudging the river at the proposed 'hot-spots' will result in the distribution of PCB's to the water oalimm, some v*>ich will become attached to suspended solids. Contact with molecules of PCBs and with contaminated suspended solids will greatly increase the chances of exposure of fish population to poisons, and will no doubt result in additional and Increasing fish kills. This action would do mere to impede the re-vitalization of the fishing Industry than to accelerate it. Further, the entire fish population of the river to the NT Bight will encounter these PCB contaminated sediments as they flow with the current.* Response tin See response to oomment No. 8. Ccaaent 111 "Increased pollutant loads will be placed an the dawn-stream raw water treatment plants as a result of the dredging operation. According to the EIS Statasent, no recent out-of-the ordinary problems have been reported by the treatment plants using the Hudson as their sole water source.* Extensive dredging operations (1977) by the Department of Transportation at Rogers Island in Port Edward were monitored and no significant PCB transport was noted within a mile dowistrems. These results are documented and published in Paper #65 by the New York State Department of Environmental Conservation. Since the closest water supply intake to dredging activity is three miles downstream (for the full-scale project) and 26 miles downstraas (for the reducedscale project) no increased pollutant loads on these treatment plants are expected. Also, see response to comment No. 8. 5-7 HONS 009549 Cc--fit 012 "The EIS and the supporting docueenta are prepared to provide assurance that all known technological efforts would be nade to protect the huaan inhabitants of the region during and after the dredging operation. However, a reoent technical report reviewed Chen, a Engineering News on Feb. 8, 1982 placed in question the previous notions of harmful hunan health effects of PCB's." Response 12 W axe aware that a recent report indicates that PCBs may not be as harmful to huaana as previously recognized. However, we believe that the safety precautions presented in the EIS are certainly in order until more conclusive scientific evidence is presented. Cossemt 113 "In as nuch as dredging operations are standard operating procedures for many technological endeavors in our society. I assure that the proposed iVimuml ml I.si did not mean to esphasise demonstration of dredging, these demonstrations and lists of land containment storage for toxics will presumably provide seme neceseery nsepenes >13 See response to ixiraent No. 6 Coront 114 Concerns raised for ocapenaation of economic loss resulting from decreased property value of lands near the dredging operations or disposal site...and for creation of a compensation fund as a mitigation measure... are not adequately addreeeed (in the FEIS response) or the letter from the Solicitor General." Response 114 the NYSEEC's proposal for oenpensation is fully discussed in closing state* menta submitted to the New York state Industrial Hazardous waste Facility Siting Board. See Appendix G of this document. Corasnt 15 ..Clarify the non-applicability of RCRA to this disposal site." Response >15 The high concentration of FCB (over 50ppn) in the dredged spoils makes the disposal of this saterial subject to T9CA regulations. Hie elutriate toxcity test required under RCRk was carried out and the material wes not Aown to be a hazardous wests. HONS 009550 5-8 aowntr, since TSCA and KBK regulations may be integrated at scam point in the future, RCRA requirements concerning closure, post-closure care, gromdweter monitoring, and financial responsibilities will be Incorporated into this TSCA permit. Oesemnt *16 "the primary method of PCB transport in the water colunn whether dissolved or adsorbed to particulates has not been clarified. Resolution of this uncertainty might allcM the dredging operation to focus on these 'hot spots' which if dredged would remove those sources contributing greater mounts of PCB to the water ooltmm. It is not stated in the NYSEEC dredging plan (Appendix 8) whether the results from the planned study by Malcom Pimie, Inc. ("PCB Release Fran Hudson River Sediments'') which is designed to investigate and possibly resolve this uncertainty will be used to modify the 'hot spot' dredging plan or reevaluate the 'no action' alternative." The comment overlooks a more fundamental question of vrfiich PCB transport mode, i.e., desorption or scour, has a greater influence on the contamination of biological resources in the river. It inplies that the mode moving the most PCB in the systmn has a greater role in contaminating the fishery. Further, this ccnment also overlooks an obvious cost factor associated with prioritising hot spots to be removed simply based upon a concept of annual contribution. The study mentioned is being conducted by the University of Michigan, not Malcolm Pimie. Inc. The information resulting from work proposed by Or. Zimsie, at fteneaelaer-Polytechnic institute, in addition to the University of Michigan study, should permit incorporation of a prioritizing scheme based upon hot spot credibility as well as desorption capacity in assigning areas to be dredged within the Hopson Island Pool. Ccnment <17 "Several 'hot spots' were identified as productive wetlands which provide quality habitat and storm protection. No mention is made in the FKIS of the feasabllity of wetlands restoration or creation in these locales. Concern was also raised over dredging 'hot spots' that are now covered with clean, uncontaminated sediments sines their present contribution to PCB levels in fish flesh and drinking water supplies, even during storm events, is believed by several respondents to be very seall. Response to these concerns should be more fully discussed in Section 2 of the PEIS.* Response #17 The predxsdglng monitoring plan outlines criteria which will be utilizsd in determining which hot spots, including wetlands, will be dredged. (See Appendix D for criteria.) The EPA reccsmende that wetlands dredging be carried out only if data from the predredging sampling progran indicate that wetland hot spots base a higher desorption rate than non-wetland hot spots. The hot spots, as designated by OBC, are not considered stable. The primary reason far the project is to remove the hot spots and thereby prevent further PCB migration and volatilization. MONS 009551 5-9 There are unresolved questions concerning the long-term stability of hot spots. Although peak sediment KB concentrations In the Thcapeon Island (tool ten! to be located beneath a thin layer of cleaner sediments, recent sampling by EPS and DEC in this area (1981) indicates that surficial concentrations are still oonsidentioly elevated in the project area. The question of stability of existing hot spots in regard to scour by high flax events cannot be definitively answered at present. Additional pre-dredge saapling and analyses should permit a clearer perspective on the lspoctanoe of this question. 5-10 HONS 009552 ABBREVIATIONS USED Citizens Advisory Comaittee curie centimeter United States Amy Corps of Engineers cubic feet cubic meter cubic yard draft environmental utpact statement environmental iapact statement United States Environmental Protection Agency United States food and Drug AAninistration foot gram hour inch kilogram kilometer liter Lawler, Etatusky and Skelly Engineers pound meter million electron volts milligram mile millimeter Malcolm Pimie, Inc. millirem nanogram National Environmental Policy Act National Institute for Occupational Safety and Health New York State Department of Environmental Conservation 6-1 MOWS 009553 OTSDOH NYSDOT 06W1 PCB pcir pci PT*> ppt SAC sec sq as sq TSOk USW USfW ug yr ABBRBOxnCNS USED (Continued) New York State Department of Health New Yack State Department of Traneportation Occupational Safety and Health Administration polychlorinated byphenyl polychlorinated dibenzofuran pioocurie parts per billion parts per million parts per thousand PCB Settlement Advisory Ccemlttee second square centimeter square meter Toxic Substances Control Act United States Department of Agriculture Uhited States Fish and Wildlife Service microgram year HONS 009554 6-2 CORRESPONDING METRIC AND ENGLISH S2UIVAUNTS Celsius CC) centimeter (cm) cubic meter (cu m) gram (g) hectare (ha) kilogram (kg) kilometer (km) liter (1) meter (m) metric ton (t) microgram per gram (ug/g) microgram per liter (ug/1) milligram per liter (mg/1) millimeter (mm) nanogram per liter (ng/1) NOIEs 1. an approximate equivalent 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 (ppa) part per billion (ppb)| part per million (ppm)1 inch (in) .1 part per billion HONS 009555 7-1 list or n&mRBs This final EIS waa prepared by the following EER Region II staff. Ha. Anne Norton Hiller Hr. Richard H. tialka Ha. Robin Stohn Chief, Ehvironoental Inpacta Eranch Chief, New York/Virgin Inlands Section Project Officer/Ehvironaental Scientist HONS 009556 8-1 APPENDIX A FINAL BWIRCNMQTCAL MONITORING PUN HONS 00955 7 A-l HUDSON RIVtl PCR RSCLAMAT10N DEMONSTRATION PROJECT environmental monitoring program Jana 19(2 toug of Wacar Rataarch Division of Rictr Nov Tork Staea Daparcvanc of Inrironvancal Conaarvaeion Albany, Hav Torlc MQNS 009558 PREFACE . The Hudson River is distinguished as perhaps tha world's meet severely PCI-contaminated aquatic ecosystem. Several measures undertaken to raduea cba major external sourcas of PCSa hava raducad chair lavals is cartain " compartments of chis syseas. Tha proposad raaoval and isolation of a laria ass of PCls associated with highly contaminated sad inanes in tha Upper Hudson is designed to acealarata raduecioo of PCSa eo acceptable levels in tha rivar's biota. To assure that projected benafits of dredging and encapsulation of highly contaminated sadiaants are attainable, and to aininiza the hunan health aad ecological costs of tha process, a comprehensive nonieoring strategy has baan developed. Tha discharge of PCSs to cha Hudson Hlver by two capscicor manufacturing facilities in cha towns of Fort Edvard and Hudson Falla is baliavad to have bagua in 1947. It was not until 197S that a problaa was parcaived, whan lavals of PCla in Hudson River fish ware shown to ba substantially highar than limits sat by cha United Scatas Food and Drug Administration for inter stats commareo. Proceedings against cha General Electric Company (G.E.), cha ownor of tha discharging facilities, for alleged violations of Haw York State's Conservation law resulted in an agreement between G.E. and cha Haw York State Department of Environmental Conservation (HTSBEC). Tha agreement provided for a reduction in PCI discharge from an estimated level of 14 kg/day in 1972 to 0.001 kg/day in 1977. In addition, cha agreement established a $7 million program including Cha investigation at cha extant of rivor contamination, tha astaaaMnt of medial alternatives, and the implamoncaeion of remedial measures. tha resulting investigative effort demonstrated that a large mass of Pda rasidod in tha sediments of tha Upper Hudson and in former river sediments sxpesed whan cha Fort Edward Dam was removed in 1973. The removal of ehis dam, doweatraam of cho two PCI discharges, appears to have boon s major event in the history of PCI transport in tho rivor. Hot only wore noar-shora deposits * exposed to cha atmosphere, bat s large aaaa of highly contaminated sediments -- was aada available for scouring and transport downstream. Of cha nearly 300.000 kg PCIs estimated to have been discharged to the river, approximately 30.000 kg to 44,000 kg were associated with the exposed river sediments known as remnant deposits. Approximately 137,000 kg PCIs reaida in tha sediments of an 10 las reach of eho Upper Hudson. An additional 74,000 kg PCIs have baan deposited in cha sediments over the 240 km length of tidal river and estuary from tha Federal Dam at Troy Co tho lottery on tha southern tip of Manhattan Island. Tho romnant deposits stare stabilized from a highly erodibla stats in 1974 and 1973 by rip-rapping. In addition to this action, cha elimination of the PCS discharge, and cha relatively mild hydrological regime following a 100-year flood in 1974, hava contributed to a substantial decline in tha PCI levels observed during the past five years in fish, macro invertebrates and in cha rivar's base flow. However, it is suspected that PCIs in the sediments of the neper Hudson art available for indefinitely prolonging cha contamination of shery resources to unacceptable levels. This theory and cha present opportunity to racritve a large PCI mass associated with cha nose highly concainatad sadiaants, at a reasonable cost, support an environmentally protective action of removing end isolating these sediments MGNS 009559 The proposed Hudson Rivar PCI Reclamation Demonstration Projsee will dradg* selected areas in an 8.4 la raaeh of eh* Hudson River extending from cbo town of Fore Edward downscraan eo eha Thompson Island Dan. Targaead for ramoval ara 50,000 kg of PCBt in- 500,000 s' of sadiaant. The dradgad notarial will be eoncainad in a eliy-lined siea adjacanc to eha rivar ae eha .pstream ana of eha projaec araa. The proposed containment siea eensises of a aarias of seoraga calls and ponds, having a eoeal exposed water surfaca araa of 16 ba. .taring a sin-month period, sadiaanes will ba punpad into eha siea. Procsss waear ae eha siea will ba eraaesd prior co discharge eo eha rivar. Upon completion of eha dredging eha siea will ba cappad wich clay. Biua haaleh, acological, and oehar inpacea of eha project have baan aaaassad as pare of a langehy regulatory process. Howavar, additional research and aenieoring is required eo opeiaiaa tha banafies of eha projace and eo aasmra that public haaleh and acological value* ara not compromised by cha project's short-term activities or eha possible long-eara coneaiomane of eha dredged material. In.order eo address ehasa naads, eha monitoring strategy prasonead in this document employs eha resources of eha Unicad Seaeas lavironmsncsl Proctction Agency, Baitad Seaeas Geological Survey, NTS Department of Haaleh, and eha KTSDtC in addition eo private acadamie and eaaaareh inseieueiona. Tha accelerated recurs of peg* in tha river's fishery resources eo acceptable levels is eha major anticipated banafie of eha raelaaeion project. Towards optimising eha banafies, eha mass of PCS* eargacad by eha projace mast ba precisely defined and carefully removed. In 1977 over 1300 cores and sod 1mane grab* wars collacead in eha araa proposed for dredging known as tha Thaarpaon Island Fool. Analysis of chase sample* parmiecad cha initial .efiaition of "hoe spot" areas having an average PCI concentration axecoding 50 ppm. Tha resoles also danonscracad chat while surficial spdimane . saosaaerationa vara exceedingly high in hoe spots, eha mamimam ?C> comeantracion* wars generally several inches below eha surfaca. Prior eo dredging,' additional investigation is required eo baeear define eha horixeaeal _ area and depth to vhieh sodimanta moat ba removed. To assure chat surficial sadiaant Pda in a pose dredging repose approach background levels, eha definition of dredging areas will ba followed by monieoring during dredging to improve the effectiveness of eha removal of eha coneaainaead sediment layer. Additional survey work after eha dradgad srasa have assumed a aora stable rapoea, will aid an aasasamant of eha river's response to dredging. Tha hiaan haaleh and acological concarn* being addressed by eha monieoring plan relate eo two situations eraaead by eha projace from which PCS* could bo dispersed eo the. anviroiaMne: eha canesinnane araa and tha dredging sites, goeh soureas have two distinct phases in relation eo choir potential for releasing PCI* to eha anvironaane. During tha ralaeivaly shore period of dredging, PCS losses from eh* containaanc sic* will occur prisurily from tha surfaca of eha siea eo eha semaphore and from eha discharge of process waear co eh* river. Over eh* long earn, following capping of eh* siea, PCg lossas should b* graaely reduced and occur, if ae all, by migration wich groundwaear and with gasses amieead from cb* siea. Air, surface waear, and groundwaear, and plant monitoring strategies have baan designed for protaceion of workars ae ha siea and for human haaleh and economic interests of naarby residents and HONS 009560 i il Ac the dredging sices, downstrain losses of PCBs due co resuspension during dredging, in addition eo natural acouring resuspension and daaorption procaaaaa occurring over an extended pariod altar dradging, ara of concarn to ha river's biological raaourcaa in addicion to drinking wacar uaaa. Both long-tara and short-term huaan haalth and acological concarna of PCB transport in cha Hudson ara addraaaad by tha wacar aonicoring program. Project control in raaponsa to raal-tima analysis of data, rathar chan pura data eollaetion, ia implicit to eba daaign of boch tha monitoring plan and tha reclamation project. Rumen health-baaed standards for PCBs in air, wacar, crops, and fish serve as the primary bases for control aspects of cha aonicoring progras. The overall monitoring program is a mulei-disciplinary multi-institutional effort coordinated by and cha imnediact responsibility of Cba Division of Wacar, of the NTSDEC. Tha following dacailad aonicoring plan, developed by NTSDEC through cooparacion with a number scientists and engineers, presents air, wacar, plane, aquatic biota, and sadimane monitoring strategies as sactiona. Several investigations supporting tha monitoring plan in addition eo a definition of resources raquirad to axacuca the workplan ara provided as appendices. The responsible parties within NTSDEC for the development end execution of cha monitoring program ara: . Dr. Mark ?. Brown, Research Scientist IV Mary 1. Warner, Research Scientist II Bureau of Wacar Raeaareh Haw Tork State Department of Environmental Conservation loom BIS 30 Wolf Road Albany, New Tork 12233 HONS 009501 HUDSON 81VHL PCS RECLAMATION DEMONSTRATION PROJECT EHVIORNMENTAL MONITORING PROGRAM Kay 1982 ' TABU OF CONTENTS Pago Preface.................................................................................................................................................... ..... Lift of Figure*.................................................................................................................................i* Lift of Table*.................................................................................................................................- SECTION I. MONITORING ATMOSPHERIC LEVELS OF PC3S NEAR SEDIMENT OREDCINC AND CONTAINMENT AREAS Introduction......................................................................................................................................I-1 Background Potential Source* of PCI Eniaaion............................................................................... 1-2 PCI Behavior Theory and Pradietiona ........................................................................ 1-2 Air Quality Conaidarationa 1-3 Monitoring Strategy Pra--dredge Monitoring............................................................................................................ 1-4 Intenaive Monitoring . . ....................................................................................................... 1-4 Bautina Monitoring................................................................................. -...............................1-7 * Methodology Fiald and Sapling Procedure*......................................................................................1-9 Analytical Procedure a................... .... . . ...................................................................1-9 Data Analyaia.........................................................................................................................................1-10 teferencea............................................................................................................................................. 1-11 HONS 009562 tails of contents (Continued) . SECTION II. MATER MONITORING PLAN FOR THE HUDSON RIVER, CONTAINMENT SITS, AND POTABLE WATER SUPPLIES . Introduction.................................................................................................................................... II-1 Background . PCI Losses Associated with ProjcceActivities ................................................ Uatar Quality Consideration* ........................................................................................ Assassaent of River Recovery ....................................................................................... II-3 II-3 II-A Monitoring Strategy USGS Water Monitoring Prograa ................................................................................... II-4 River Studies During Dredging......................................................................................II-8 Potable Mater Supplies..................................................................................... Containment Sica Monitoring Activities................................................................... II-8 II-8 Methodology Field and SamplingProcedures...................................................................................II-11 Analytical Procedures................................................................... Quality Assurance .................................................................................................... 11-12 Data Analysis..................................................................................................................................... 11-13 References.......................................................................................................................................... 11-15 II SECTION III. PCBS IN TERRESTRIAL VEGETATION GROWING NEAR THE SEDIMENT CONTAINMENT AREA Introduction ................................................................................................................................. III-l Background....................................................................................................................................... ZII-2 Monitoring Stracegy.................................................................................................................... UI-3 Methodology......................................................................'........................................ til-* Data Analysis.................................................................................................................................. UI-5 References....................................................................................................................................... til-6 HONS 009563 TABU or CONTENTS (Continued) SECTION IV. PCBS IN FISH: LONG-TERM MONITORING OF HUDSON RIVER FISH AND THE DSE or CAGES FATHEAD MINNOWS (PIMEPHALZS PROMELAS) A MONITORING PROGRAM IN THE UPPER HUDSON RIVER Introduction ...................................................................................................................................... 17-1 lackgrouad Contamination Charaetariatic* ................................................................................. 17-2 Hiatorieal Data and Tranda........................................................................................ 17-2 Applicable Fadaral aad Star* Standard* .............................................................. 17-2 Economic Impact* ................................................................................................................... 17-3 Meaitariat Strategy Monitor inf Daaijn I......................................................................................................... I7-A Methodology............................................................................... .... . . . fV-4 Collection aad Preparation of Fih.................................................... IV-A Analytical Hatboda .......................................................................................... 17-7 Data Analyeia . ............................................................................................... 17-7 laapenaible Partiaa......................................................................................I7-S Raportiaf Sebodula ........................................... .... ..........................................17-9 Monitoring Daaign II................................................................... ..................................... 17-9 Methodology.................................................................................................................. IV-9 Expoaura and Praparation of Fiah.........................................................17-9 Data Analyeia.................................................................................................... 17-11 Raaponaibla Partiaa ............................................................................................... 17-13 Raporting Scbadaia.............................................................. ..................................... 17-13 Rafarancaa.......................................................................................................................................... I7-1A HONS 009564 iAu we wuct tii'* is (Cone inued) SECTION V. ?CBS HI MACROINVERTEBRATES: LONG-TERM MONITORINC WITH CADDISFLIES AMD ARTIFICIAL SUBSTRATE RESIDUES AND BIOACCUMULATION MONITORING IN THE UPPER HUDSON RIVES USING THE AQUATIC MIDGE (DIPTERA: CHIRONOMIDAE) ' Introduction................................. .... ................................................................................................... Background General.......................................................................................................v-J Short-term Monitoring ........................................................................................................ 7.3 Long-term Monitoring........................ ............................................................................... 7.4 Monitoring Strategy Short-corn Monicoring ........................................................................................................ 7.4 Long-cera Monicoring ........................................................................................................ y-g Methodology Field and Stapling Procedures..................................................................................... P-9 Analytical' Methods................................................................................................................ v-12 Responsible Partita ............................................................................................................. y-12 Financial Conaidaraciona ............................................................................................... 7-13 Quality Aasuranes/Qualicy Concrol ............................................................................ V-13 Data Aaalyaaa Short-tarn Monicoring ........................................................................................................ 7-14 Long-Cara Monitoring ........................................................................................................ 7--14 Raporcing Scbadula ................................................................................. 7-14 Litaratura Citad . . '................................................................................................................7-13 SECTION 71. SEDIMENT MONITORING PROGRAM Appendix A. Request for a Propoaal: Volaeiliaacion of Polychlorinated BiphenylI (PCSe) froa Concaainacad Hudson River Sadiaanca and Hater. Appendix B. Request for a Proposal: Rtlaasa of Polychlorinated Biphenyls (PCBa) froa Concaainacad Hudson River Sadiaanca Appendix C. Fish and Preparation Procedures for Contaninanc Analysis vill. HONS 009565 LIST 07 FIGURES Localism of meteorological unit and air aaapling units during background, intensive, and routine monitoring ...................................... Multiples! sampling sices in che Hudson River ........................................... Multiplace and eaddisfly collection sicos-Upper Hudson River . . . Short-term exposure packec containing mature larvae of Chironomus tentans Fabricius (Dipeara: Chironomidaa) ..... . . . . . . sm 1-3 7-7 7- 7-11 MONS 009566 lx LIST OF TABLES PCS air sup It eolltction schadula or six-month dradging stasan . . 1-5 SPOCS discharge ptrmie affluent limitations and monitoring requirements which apply to cha containment sita affluent dorin* tha dredging oparacions ............................................................................ It-J Annual sampling matrix for USCS Hudson Rivtr PCS studits........................n-7 Sampl ing matrix for 1TTSDEC uatar studias during tha six-month dradging saason.................................................................................................................. IJ-9 Summary of prasant and futura affort and associatad valuas of tha recreational fisharias of Cha Hudson Rivar ................................................ IT-3 Ganaral 1981-83 Hudson Rivar ?CB sampling dasign for fish monitoring................................................................... .... ................................................... 17-3,6 Exposura and location schadult for Dasign II - fish monitoring program........................ -............................................................................................................17-10 PCS data arrangamanc for cha Chraa-factor dasgin of analysis of varianea.......................................................................................................................................17-12 Avartga PCS eoneantrations in watar, maltiplata rasiduas, and caddisfly larvaa, 1977-1980 ...................................................................................... 7-5 HONS 009567 SECTION I. MONITORING ATMOSPHERIC LEVELS OF PC3S NEAR SEDIMENT DREDGING AND CONTAINMENT AREAS Bureau of Water Rajaarch Divijion of Wacar NTS Departuane of Environaancal Conaarvacioa HONS 009568 IHTWJDCCTION Based upon previous research concerning the environmental behavior of polychlorinated biphenyl (PCS) compound a (Doskey and Andren, 1981; Pal at al., 1910; Kalaas and Kalncs, 1979; Pavlou and Dexter, 1979; Paris at al., 197877' it ia antieipatad that activities aaaociatad with eha propoaad drsSging and ntsinmant of Hudson River PCS-concaminatsd sediments will raaule in loaaaa of tnoaa eautsninencs to the atmosphere. Althoufh eoneantrations of ?CSs is tha air at drad|in* and containment araaa art not axpaetad to reach critical levels (OIEPA, 1981; Malcolm Pirnia, Inc., 1980, 1981b), it ia necessary to monitor thaaa levels to provide for protaetion of public haalch and tha environment. Air monitoring for tba propoaad Hudson aivar PCS Reclamation Demonstration Projaet baa boon addraaaad in tba Response to jjhe Exacut ivc Summary of tha Draft Hnvlroemental Impact Statement prepared by tba Haw fork Scats Oaparcaant oTTjpr ironmencal Conaaraation (1TT3DEC, 1981b). Tba aonitoring aetivitiaa daaeribad thara have boon revised to ineluda recommendations from HYSSEC lagion J, HYSDEC Division of Air, WYS Dapartaanc of Haalch, Boyca Thoapson Inaticuca for Plant taaaareh, Inc., and tha Industrial Hazardous Waste Siting loard. Tba air aonitoring program daaeribad below ralaeas primarily to tba period during whieb contminatad sediments ara removed from tha river and transferred to tba containment aita. Prior to chat time, baseline monitoring vill bo carried out both by eha HYSDEC and as part of tba program carried out by tba leyca Thompson Institute for aonitoring PCBa in terraatrial plants (Section III), loginning in Hay, 1981, atmospheric lavala of PCSa vill be measured at tba propoaad containment site as part of a ataeavida progrmt conducted by -HYS0KC Division of Air. Samples are collected every six days at all sites in tba sampling network and seat to the HTS Department of Health laboratories for traction and analysia. Sampling and analytical techniques employed in that prograa (HTSDOH, 1981) and ia tba air/plane study (Section 111) will ba comparable to those need ia tha program daaeribad below, providing a basis for intarcomparisen of data. After tha containment areas ara eapped, aonitoring procedures will be initiatad that will accommodate comparison of atmospheric PCS concentrations before and after the operation of the project. These .procedures will be continued until m^ient levels at the sits ara at or below background lavala measured prior to the project. - Tha general objectives of tha air aonitoring prograa ara to: naasura ambient levels of PCIs in order to determine early ia the project, and with changing conditions, ubethar significant codifications ara required in tha design and operation of dredging-related activities; document worker exposure levels; anticipate critical werkar exposure levels so chat protective equipment aay ba used; document ambient levels related to nearby residential and agricul tural areas; and anticipate critical exposure levels for local residents end agricultural crops so thee contingency measures aay oe implemented. HONS 009569 1-1 BACKGROUND Pet*ntialSourea:i_of_PCS_Emi*aicm Foeancial PCB loi eo eh* air during eta* projtee't operation exists whara meaminacad aadiaanea ar* axpoaad or where dissolved PCS concentration* ineraaa* dua to raauapanaioa of contaminated sad inane j. Primary eanearn for lucta leaaaa ia foeuaaad an eh* large araaa of axpoaad' sad inane and eaneaainacad waear bald, at eh* containment tie*. Laaaaa aatoeiaead with eh* dradging activities ar* axpaeead ea ba aucta lower, alchough taduaanc will ba axpoaad on eh* bargaa and volacilizaeion may b* anhanead during eh* praeaaa of slurry foraaeion at eh* barga unloading araa. Tha eoneaneraeiona of PCB* io eha river ar* nee axpaeead eo ria* eo ericieal level*. Th* rttulea of prtviou* aonicoring of dradging aeeivieiaa auggaac ehac downacrtam loaaaa fraa eh* dradging tit* will b* lata chan ewe pareane of eha total dradgad aaaa and ehae any tffacta will not b* dactecabl* nor* chan e.vo ail** downacraaa (NTSDEC, 1911b). Th* propotad tie* for aneapaulacion of PCB-eoneaainacad aadiaanea eonaiata of a 16-ha eoneaiaaanc araa, dividad into two ealla bp a control dike, and a eraaeaane araa with 6 ha of roughing,--aeoraga, and- surge pond a. Approxiaatalp on* acra of aadiaanc could b* axpoaad whar* eh* influane pip* aapties into eh* containment call. If dradging proeaodo u sehadulad, eoneaneraeiona of PCS* in ehoaa aadiaanea ar* axpaeead eo b* approxiaatalp 100 ppa ia eha firae poor of dradging and SO ppa in eha aaeond poor (HPI, 1980). Tha remaining portion of eha eontainaanc eall, eovarad wieh eontaaiaatad water, will progressively daeraaaa aa eh* eall ia eowarad wieh a eaaporarp cap. CaatMinatad waear will alao b* axpoaad in eha eraaeaane faeilicp pond*. It ia atiaatad that aoluhl* PCS* ia eh* water at th* eontainaanc ait* will b* ia the rang* of 10-20 ug/1 baaad upon predicted aadiaenc eoneaneraeiona and doaorption theory OfTSDCC, 1981b). PCI lohawior Thaorp and Prediction* .. lb* traatport of PCS* aereea th* air/watar intarfae* ia largely gowaruad bp two ptapaieal proportiaa: water aolubiliep and vapor praaaur*. Water aolwbilieiaa haw* boon determined for eh* individual PCB compounda and eomnareial Aroclor nixturaa, but raliabla vapor praaaur* daca ar* available for only a few PCB iaomara and eh* eomnareial mixture* (Watteott assd lidlanan, 1981; Waateoec at l., 1981; Murphy * al_., 1981; Hackay at al.. 1981). Bane*, indirect calculation* of eranafor race* baaad upon theta two proportiaa ar* ~~unc*rt*in. Direct naaauromenta of aqueous and vapor eoneaneraeiona in laboratory tank caaea, uaing aaturattd solution* of Aroelora or eoneaainaead aodimonta, have boon performed (Dookay and Andran, 1981; Tofflamir* at al.. 1981; lading, st *1., 1978; Pari* at aU, 1978). Raaulea from that* experiment* vary widely, howavor, and prediction* of volatilization baaad upon the** data ar* even further complicated by eha efface* of weathering of individual PCI eoaponanta, aaroaol foraaeion, eurbulanea, and eh* phptieal and chemical propertie* of evaporative aurfaet*. ." Uaing eh* limited information available on eh* behavior of PCB* ac eh* vr/water interface, predictions hav* bean sada concerning volatilization rate* HONS 009570 1-2 associated with various procedures eaploysd ia handling Hudson tivr PO-eoncMinatsd aadiaants. Ths aaisaien rata o< PCSs froa cones*insced water at tha eontainaant fita ha a baaa aatiaatad by Maleola Pirnie, Inc. (Mar eh, 1981b) using asasursd amission rata* tiM a saturated Aroclor 1242 solution 'Batling, 1978). Tha calculated aaisaien rata eoabined with disparsion stiaataa and aataorologieal data baa baaa naad to predict various air PCS.coeeantrsciena. thuring the first year of dredging, 8-hour avasata eoacantrations of 0.3 ug/a3 at tha eontainaant sits and 0.2 ug/a3 at tha naaraat rasidanca hava baan predicted (MPI, March, 1981b). It has also boon aatiaatad that if aquaous PCI ceaeaatratiana axceod 28 ug/l (MAF08A) or *3 ug/1 (MPI), and critical aataerolegical conditions oceur as wall, tha PCS sir eaaasatratian will exceed the 1.0 ug/*3 (24-hour avaraga) guideline rasoaaanded by tha MIS Dapartaaat of Baalth (USZFA, 1981). an analysis of the behavior of PCls ia tha centaiaaoat calls, baaad upon azpacead influent lediaent mixtures and desarptiaa partition coefficients, auggasti that a dissolved concentration of 44 ug/1 will net likely be axeaedad (USZPA, 1981). Zlutriate tests conducted by MPI indicate ehac, even under worst case conditions, tha dissolved PCI cencancration will not exceed 29 ug/1 (Tofflaaira, 1981). A study, supported by tho project, will be conducted to aore accurately assess tha aces eaiasion rata of PCls froa tho eontainaant sita (son Appendix A). Ibis study, to be cauplatod before dredging coaaaacas, will be based upon flea aeasursaaats of these PCI coaponants which are present ia centaainatad eediaeatl froa the proposed dradging area of the Budson liver. Tha transport of PCls across both the leduuent/air cud water/air interfaces will bn is Ml nod error the range of taaperacares anticipated within the eontainaant lagoons. Lr Quality Considerations Predictions concerning PCI air concentrations at tha sita and at tha unerase sensitive receptor indicate that applicable air quality guidelines will oat be violotad. Tho current federal asiuirni--ural standard far PCls (21 CPI . 1910.1000), based upon reesanendstions aado ia 1988 by tho Jaaricoa Coaforsaco of Covaiwaowtal Industrial lygisaists, ia 1.0 ag/a3 for PCI aixeuraa containing A2 poreant chlorine and 0.3 ag/a3 for aixturaa containing 34 pertant chlorine (USIHW-ITtOSg, 1977). Tho latienal Institute of Occupational Safety and Baalth (non) has rocoaaandad that tho level be reduced to 1.0eg/a3. Those values are tine-weighted averages for opto s 10-hour workday, AO-hour workweek. Tha MTS OaparOnac of Health has racoaaandad an sapient air guidaliao of 1.0 ug/a3 (24-bour avorags) to procect tho local population. Praliaiaory results froa studios on PCI upcake by aowaral species of terrestrial pleats (luekley, 1980) snggost that agricultural crops grows in the vicinity of tho eontainaant site could becoaa cootsainstod beyond current PDA Units. By extrapolation froa PCI valnaa aaasured ia soaplss of corn, alfalfa, and tiaethy grown in thrso PCI air concentrations (0.08 - 0.19 ug/n3), it is predicted that crops grown in air exceeding 0.03 ug/a^ can aeeuaulaea PCSs beyond tbs 0.2 ppa rOA limit (Buckley, 1981). Further studies ere being eonduetad to substantiate these estimates. HONS 009571 1-3 MOHITORINC .STSAUCT The monitoring strategy is divided into three phases which, depending upon information requirements, differ by sampling locations and frequancias. Prior '0 dredging, air PCI concentrations at tvo locations, along the river and at ,ie containment sice, will be determined to verify previous background measurements. At the onset of dredging, intensive sampling will be conducted at the dredge and barge unloading areas end near the ares where sediments ere introduced Co Che containment site. This will continue for at least two weeks or until it is established that air concentrations at these locations are below critical levels. Routine monitoring will continue throughout the dredging season unless PCI air levels at a given location becoam critical. In that vent, intensive sampling will be reinatituted at the area of concern until the problem is resolved. Final sice selections will noc be made until the containment sice is constructed. Consideration vill be given to the availabilicy of power sources, suitability of terrain, avoidance of operating space required by dredging and ocher equipment, and protection from vandalism. Sampling units will be ' situated as close as possible to the points of concarn to obtain the most reliable estimates of exposure levels of workers, residents, and crops to atmospheric PCSa. . ~~ A mamary of che proposed sampling strategy is presented in Table 1-1 and the sampling locations for. the three phases of monitoring are shown in Figure I-l. The progrmi is designed to minimize both the number of sampling tmics required and their movement from site to site and to allow flexibility in che sampling schedule. fro-Dredga OonitoTim In' order to document baseline levels of PCIs in the air during the period just prior to dredging and to compere these data with detarminacione from previous peart, air samples will be collected along the river and et tha . tentaiament site (Figure 1-1). All aampla collection periods will ba 24 hours, and five successive collections will be made at each location (Tabla I-l). Intonsive Monitoring . Intanaiva monitoring oc thm onsac of dredging will roquirt five continuously opurating sampling unit* collecting 24-hour samples at each location (Tabla 1-1). An additional unit will be maployad as a backup. This schedule will bu continuad for at lsast two weeks or until five successive FO values at a given sits ara lass than 1.0 ug/m3, If that level it exceeded, eight-hour sampling periods will be initiated to determine whether eight-hour average health standards ara being violated and to resolve idiether critical levels can be associated with any particular period of tho day. Unit 1 will be used to oonicor air PCI concentrations asseciscsd with in-river dredging activicias sad the cumulative westerly dispersion from tho sits and unloading area. Hydraulic dredging will be monitored for only five '-ys sinee minimal losses of PCIs dwo to volstilizetion are sxpocted with this 1-4 HONS 009572 TabU 1*1. PCS air saapla coll act ion achadula (or i *ix-oncfi dradging nmo. Saaoliag Unit Location Purpoaa Frequency~Durat ion Mo. Sanplaa a. moazscs mqmitorihc 4-2 Containxone Background, lici on-aita Daily-ona uoak A-l Unloading Bcckground- tru n*r river Oaily-ono waak 5 5 t-2 1-3 4 1-5 C-L C-2 c-a C-3, C-5 Dradga araa On-aita, noar iafluanc pip* North of air load lag araa Sooth of oar loading araa Sica boundary B. IHISHSIVB MOHITOIU1W Uorkar axpoaura, woatarly diaparaion Daily-two uaaka (clanahall) Daily-ona waak (hydraulic) On-aita uarinua lovala Daily-two uaaka Uerkur ind resident opowrti Daily-two uaaka 9stkar cad resident ccpoinrtfl Daily-two uaaka Upper limit to offsico Daily-two uaaka c. boutihe mtmotac Dradga araa Horknr axpoaura, uaatarly diaparaion Oaca ovary ochar weak Onloadiag araa Uorkar and resident axpoaura One* avary ochar waak Coacaiaaaat aita On-aita aari.aun lavala Daily SW boundary Resident axpoaura Daily SI aad MS boundary Crop axpoaura Dapandanc upon aacaorological condition* 14 7 14 14 14 14 -- 12 12 ISO 180 ISO 1-3 HONS 009573 / Af HONS 0 0 9 5 7 4 Containment Site Design C-3 o 600 Foot rt|ur 1-1. Locations of aMtaorologlcal unit (M) and air saopllna units (1, 2, ), 4, and 6) durlnf background (A), Intensive (#), and routlna (C) Monitoring. Sec Table 1 for further dpta Us. type of dredging (MP1, 1981c). When clamshell dredging commences, ic will ba monitored for can days, tinea PCS air laralt ara predicted to rise to O.OS ug/m3 (MPT, 19<le) dua to exposure of aadiaanet during chata procedure*. The taapling unit will ba loeaead at clot* to the workers at possible and at a point representing tbair greatest exposure level. This vill depend upon the tligcmaut of the dredge and scows and the prevailing wind direction. In the avaat that the 20-hour average values are greater than 1.0 ug/*7, eight-hour staples will be collected to determine whether and whan protective equipaanc will be used. Unit* 3 and A will, monitor PCS levels at the unloading area where sediment will bo exposed on the scows until it is slurried for transport to the concainaont call. The saapling units will be loeaead to the north and south of ehe unloading area ae points that base represent worker exposure levels and glso allow estimation of PCS levels at nearby residences (Figure I-i). if 14-hour soaple data exceed 1.0 ug/o3, contingency aeasures described above will be iaplasMncad. Additional aeasures could include a modification of the slurrying process-end covering the exposed sediment* on the barge*. Unit 2 vill bo usad to measure the maximum air lavels of PCS* within the containment site (Figure 1-1). During this monitoring phase the unit will be situated as .close a* possible to the lagoon influont pipe eo obtain intonation on K1 loaaos associated with filling tha lagoon. Contingency measures at the ronrslnaonf sic* include reducing the sampling period to sight hours tnd use of protective equipment if eight-hour average PCS valuoe are greater than 1.0 ug/*3. Critical eoodiciona related to oxeaasiv* volatilisation from tha cooteinmont sico may ba aneicipatad by following disaolvod PCS concentration* in the lagoon and aacaerologieal condition*. Upon authorisation from DEC, tha influont to tha lagoon and flow through tha treatment ponds will be temporarily aaltad, aad all units will be treated with e slurry solution of powdared activated carbon. _ Unit 3 will bo placed on tha tit* boundary in tha prevailing downwind direction from the active contaiimmnt cell, e* determined from misteorologieal data from tha previous year (Figure I-l). This unit will be usad to estimate bff-tite atmospheric dispersion of Kit. -- goutin* Monitorint loutina*monitoring will consist of a las* intensive saapling strategy, particularly at tha dredging aad unloading areas (Table I-l). Sampling will continue to bo performed over 24-hour periodt but at varying intervals, templing Unit 1 can bo altarnatad between the dredge and unloading areas, providing data attach of those points on a biweekly basis (Figure 1-1). Tho location of tho drodgo sampling unit will be essentially tha same as previously described. Ac tho unloading eras tho location of tho unit will best represent both worker and residential exposure levels^ Basalts from-initial monitoring will be utad in tha actual sita solset ion. A continuous record of en-sito PCS air laval* will b* gathered from saapling Unit 2, located on the central dike between the active cell and the HONS 009575 1-7 craacaanc pond* (Figura 1-1). Tha data will ba compared wish oacaorological information (cos cha onriita waachar acation to dtcamiaa any correlation batvaen PCI loaa iron cha lice and paramaeeri juch n eeaparacure, wind ipeed, and' aclar radiation. Monitoring at peripheral itationa will include a eancinuoualy oparacing eaapling unit on cha aouehweac boundary (Figure 1-1) co prsvida daca relaead to expoaure ac cha naaraac raaidanea. Daptnding upon maeeorologieal condicions, aaaple* will ba collaccad from aicbar Cha norchaaac or aouchaaac boundary taapliag unit. Daca from chaaa aaaplta will ba uaad co asaaaa cha dtgrta of pocancial crop eoncaainacion. MONS 009576 1-8 HETBODOLOCT Plaid and Saeoling frocadurtt 4 Cliaaeroniea weather station equipped with a caaaette-baaed data logger >111 begin collecting aecaorologieal data fron or near the aica at soon aa pact and power ara available. Tha parasatari aaaaurad include wind speed'and direction, wind aigsn (tha atandard deviation in wind ditaction changes over cine), rasperscure, daw point, eolar radiation, and rainfall. Data will bo gatbarad continuously at aalaetad ciaa intervals (0.3-1.0 ninnta) and racerdad on a atrip chare. Sourly and daily average valuer of each paraaatar will bo prowidad to eba PCI project daea nanagaaant ryrtaa. Tha OKC Divirion of air will ba raaponeible for initial calibration and petitioning of tha nataorological unit and for providing inatructiona to PCS Unit par tonne1 in tha calibration and naintanance of inacrusantacion. PCS Unit paraounal. will tranafar eaaaattaa fros the aita to eba DSC central office for cospnesr analytic. Cospotar printouts will ba auppliad to eba PCS Project Unit daea nanagaaant ayatan for each weak chat the unit ii in operation. dir aaaplaa for PCS analyaaa will ba collected by eba Floriail cartridge . Stthad Orrscoa, 1980). Stapling tquipsene and houainga will ba aaaanblad by tha Diviaion of Air. Paraennal froa that diviaion will alao aaaiat in petitioning cbn unita in eba field and prowida inatructiona for tbo operation aad aniatoaoaaa of tha uniea. Partonnal froa tha PCS Project Unit will ba raapoaoibla for changing cartridgea and parfaraing flow audits. Capo tod eartridgoa will bo labollod with appropriate information (a.g. data, tiaa, daration, aad loeaeioa of aaapling), packed to pravant breakage, and transport ad to tbo laboratory for analytil. A coaplatad aaapla tobaitaioo fora QRSKC, IMlc) will accoapaoy neck cartridge. Analytical Procodnraa ' Within 1A bonra after tbo aaapla ia eollactad, PCSa will bo deaorbed froa tha floriail cartridge with banana, aad tbo raaoleing aolution will bo aaalynad by gaa cbroaaeograpby (8C). Tbo detect ion liaie for 2A-hour air aaaplaa, uaing - RS OH (19*01 analytical proceduree far 6C dacaction of PCSa, ia 20'Bg/s). Quality aaaaranca proceduraa for tbia analytical aathod ara doaeribed ia . * Soction Ho. 6 (PCS Projact Lab) and Section So. A (Boyce Thoepaon Inaeienta) of tbo Quality Aaauranca Plan for tbo PCS projact (RSOEC, 1981c). Analytical ---- -- will bo tranafarrod daily to tbo PCS projact daea aanaganont ayaean. MONS 00957? 1-9 DATA AJtALTSIS The Coordinator of Environmental Monitoring for cha PCS Projaec Unit will be responsible for cha evaluation and interpretation at meteorological and ' ambient air PCS daca throughout all phaaaa at cha monitoring program, lalationships batwaan PCS concancrationa maaaurad in air samples at aaeh aica and maeaorologieal parameter] will ba examined. Ejcimatai of off-sice ambianc air PCS levels wich regard co nearby measurement] and agricultural areas will ba based on ehasa interpretations. Trends in data will be usad co estimate PCS loaaas from the sice far prediccad maeaorologieal conditions. Oats stmmarias will ba provided, daily during intensive monicoring and weekly thereafter, co eha NTSDEC PCS Project Unit, Division of Air, Region 3, NTSDOS, and Boyce Thompson Institute. Ac the end of cha first two weeks of dredging, representatives from these units will meet with the Coordinator of Eavironuntal Monitoring to determine whether the daca indicate chat less intensive routine monicoring can be initiated and whether any changes need co be undertaken in Che operation of cha project. 1-10 HONS 009578 References Buckley, E.B. 1980. PCBa in vegetacion.' Boyce Thompson Inacicute for Plane Research, Inc. Prepared for Ifnw York Seaea Department of Environmental Conservation, Albany, Haw Tork. Buck!ay, E.H. (oral communication). March Z6, 1981. ' Conversation between E.B. Bueklay, Boyea Thoapaon Inacicuca for Plant Raaaarch, Inc., Iehaca, Raw Tork to J. Tofflaaira, Mav Tork Staea Dapartoant of Environmental 'Conservation, Albany, Hew Tork. Ooakay, P.7, and A.W. Andran. 1981. acroaa tha air/waear inearfaca. 703--711. Modaling eha flax of atmospheric PCBa Environa. Sci. Tachnol. Tachnol. 19(8): Baelint, L., E. Horn and 1. Tofflaaira. 1978. Swary of Budaon liver PCB study raaulea. Tachnical Papar Ho. 31. Haw Tork Staea Department of Environmental Conaarvation, Albany, Haw Tork. Kalaaa, E.7. and G.D. Raima*. 1979. Tranapore, distribution, and toxic affaett of polychlorinated biphonyla in aeoaystaas: a review. Ecol. Modalling 8:Z23-Z31. Mackay, D., S. Pateraon, W.T. Shiu, A. Bobra and J. Billingcon. 1981. Phyaieal chemical propartiaa and behavior of PCBa. Praaancad at workataop on Phyaieal Behavior of PCBa in tha Groat Lakea, Toronto, Ontario, Decamber 10-11, 1981. Maicola Pirnia, Inc. 1980. PCB hoe spot dredging program, upper Budaon liver. Haw Tork. Draft environmental impact atatamant. Prepared for Haw Tork Stata Department of Environmental Conaarvaeion, Albany, Haw Tork. Malcolm Pirnia, Inc. Mareh 14, 1981a. Mooranda from A.M. Star for Haw Tork \ Staea Department of Environaaneal Conaarvaeion, Albany, Haw Tork. Males la Pirnia, Ine. March ZS, 1981b. Stmmary of PCB volatilization rata estimates and impact pradicciona. Memorandum to B.F. Themaa from A.M. Star, Malcolm Pirnia, Ine. for Haw Tork Seaea Daparemant of Environental Conaarvaeion, Albany, Haw Tork. Maleola Pirnia, Inc. April 1A, 1981c. Memorandum for A.M. Star for Haw Tork Staea Daparemant of Environmental Conaarvaeion, Albany, Haw Tork. Murphy, T.J., J.C. Pokojowcxyk, and C. Paolucci. 1981. Banry'a Law conacanee from equilibria aaaauramenta; large partieulaeea in PCB depoaicion. Praaancad at workahop on Phyaieal Bahavior of PCBa in tha Great Lakes, Toronto, Ontario, Deeamber 10-11, 1981. I-ll HONS 009579 ' New York Start Department oC Environmental Conservation. 1981a. quality assurance for volaeila orjanici sampling, Section 30. quality Assurance Manual for Air Sampling (draft). Ktw York Start Dtpartatnc of Environmental Conservation, Oiviaion of Air, Albany, Now York. Haw York Stact Dtpartatnc of Environmental Constrvacion. 1981b. Response to cha Executive Summary of Draft Environmantal Impact Stacamanc, Maw York Staca Dtpartatnc of Environmantal Conservation, Albany, Mew York. Haw York Staca Department of Environaancal Conservation. 1981c. Quality Assurance Plan for the Hudson River PCS Reclamation Projaee. Hew York Stats Department of EnvfronsMneal Conservation, Albany, New York. New York Scats Department of Ha'alcb. August, 1981. Polychlorinated biphenyls in aa*ianc air. Analytical Handbook. New York Scats Department of Btalth, Division of Laboratories and Rasearch, Albany, New York. Pal, D., J.8. Weber, and M.R. Overeaeh. 1980. Pate of FCBs in soil-plant systems. Rasidua Reviews 74:46-97. Paris, D.T., W.C. Steen, and G.L. Baugham. ' 1978. Role oTphysico-chemical properties of Aroclort 1016 and 1236 in determining chair face andtransport in aquatic ecoayataas. Chenosphere 6:319-323. Pavlou, S.P. and R.H. Daxtar. 1979. Distribution of PCSs in estuarine aeoeyeeems. Testing tba concept of equilibria partitioning in cha marine environment. Environm. Sci. Technol. 13:63-71. Ryan, J. December 2, 1980. Memoranda to J. Scheiet. New York State Department of Eoriromeantal Conservation, Albany, Raw York. Tofflairs, T.J., T.T. Shan, and E.H. Buckley. 1981. Volatilization at PCS fra sediment and water: experimental and field data. Presented at workshop on Physical Behavior of PCSa in the Great Lakes, Toronto, *. Ontario, December 10-11, 1981. Tofflaire, T.J. September 1, 1981. Memoranda to J'. DeZolc, New York State Department of Environmental Conservation, Albany, New York. D.S. Envirooental Protection Agency. 1981. Draft environmental 'impact - statement on Che Hudson River PC3 reclamation doonatration project. DSBPA, legion 2, New York, New York. U.S. Department of Health, Education, and Welfare. 1977. Criteria for a recooMnded standard.. .occupational exposure to PCBs. DHEW (N10SH) Publication No. 77-223. . Weatcoct, J.W. and T.F. Bidleman. 1981. Determination of PCB vapor pressure by capillary gas chromatography. J. Chrom. 210: 331-336. Weateott, J.W., C.G. Simon, and T.F. Bidleman. 1981. Determination of polychlorinated biphenyl vapor pressures by a semi-micro gas saturation method. Environm. Sci. Technol. 13(11):1373-1378. 1-12 HONS 009580 SECTION II. WATER MONITORING PLAN FOR THE HUDSON RIVER, CONTAINMENT SITE, AND POTABLE WATER SUPPLIES lorutt of Bator Ro March Oivlaion of Bator NTS DoporOoonC of EnviroiBontal Conoor-roeion HONS 009581 nrruoDccTioN The program far monitoring eh* tnviromontal impact of eh* removal and containment of ?Ci-cont Minatad sediments at proposed by eha Hudson River ?C2 laelaMCion Demonstration Project requires examination of varioua components of the aquatic environment. Tba proposed project will produSe two distinct short-car* aourcaa of PCBs ca the Hudson River water column: resuspended eoaeaainacad sediments at tba drndgn and return flow from tha eontainaanc sita. Oar tba loot tar*, tba potential exists for migration of PCJ-eoncsminattd leachate from tha eoneainmanc site into underlying groundwattra. Water monitoring activiciea are derigned to measure both long- and abort-tarn consequences of tha project in order to comply with monitoring requirements of Federal and Stata regulationa and to doeiaranc ambient eonditiona and levala of contamination of Budaon River water retoureea retui ting from the denonacrccion project. A variety of chemical and hydrological parMetara, including the cancantrationa of FCBa, heavy aotala, and miapended aolida in water, PCBs in agnatic biota, and river ataga, will be maaaured to permit an evaluation of the project'a impact on tba aquatic eavironaent. Several Budaon Hiver monitoring programa, ongoing ainca 1977, provide baaaliaa information for compariaoa wieh data gathered during and after cbo operation of tha project. Tba United Stataa ecological Survey (USCS) baa -porated ten monitoring acationa in tha Bodaon Biver, providing river .lacbarge, PCI, end tnaponded eolide data which eonatituea eha baaic information regarding PCS transport tbrougb the Bodaon Biver water colam. Tba Baw York Stata Dapartaent of Enviror--ntal Conservation (9T3UCC) has conducted widascala aonitaring of FCB lavala in both raaidant fraahwatar and migrant marina fiah apaeiaa. Tba ITS Depsraant of Baaltb (SYSDOH), in . cooperation with pYSDKC haa performed PCS amalyaas on nae-apinning eaddiafliaa ^Triehapeara: Hydropsychidaa) collected from several sites in tha Upper Bodaon Biver. In addition, FCBa are analysed in residues scraped from artificial snbatrstoa bald at 16 stations in bath eha upper and lower portions of the river. Tba above progrmas will be continued, in soma eaaaa with niner modifica tions, as integral components of eha overall water monitoring strategy for eba PCS Project Environmental Monieoriag Program. Tba combination of individual programs will provide information that will accomodate tha optimisation of project activities and eha evaluation of the abort- and long-term consequences of ebo project. Program descriptions for fiah monitoring and for caddiafly and artificial substrata residua itudiea are described in Saceiona IT and T. The water monitoring activities described below have bean da signed to permit assessment of PCB transport in both turfset snd ground wattrs from two 11-1 HONS 009582 contaminated areal, i.e. eh* containment sic* and eh* Upper Hud ion Rivar. The general objeccivei of ehii portion of eh* monitoring progrmi art es: docuMnc ambient lavail of PCS* in eh* Upper Hudson River; aaiiaii PCS crampore eo eh* *icaarin portion of eh* river; document PCI* and auapended Mdiaanc coneencraeioni near eh* dr*dg* plus* during varioua hydrological eondieiani; -- doeuMne PCS eoneaneraeion* in public drinking water tuppliei drawn fri eh* Hud ion River and anticipate critical l*vli to ehae contingency aiurei day b implemented; aaaiur* diiiolved PCBi in eh* containment lie* lagoon in ordar to antieipaea critical l*vli of volatilized PCS* in th* air; and addreu potential eoneaainaeion of groundwater! and privaca welli near eh* containment lie*. HONS 009583 sacxgiochd KI lann Associated with Project Activities leccou sediments of the Hudson River, which were a sink for PCBs during the nearly 30 years they wars discharged into cho rivor, are currently theprimary soures fro* which chs contaminants, through complex rsdiscribucion processes, ara introduced to the water column and aquatic ecosystem. Analyses at Hudson River water Maples have shown that PCBs are present in both dissolved and particulate-associated phases. ?CIs in Hudson River sediaant ara aoat highly eoncancrated in fine-grained and highly organic Bareriais (Heeling el., 1978). The partitioning of KBs between water and solids phases is dependent upon adsorption/desorption phenoaana determined by chaaical properties of the KB components and by the physieo-chaaical properties (Wildish _e al., 1980; Kanaga and (Boring. 1980; Paris it al., 1978; Halear and Johnson, 197TT, and concentration of the adsorbing solids To'Connor and Connolly, 1980; Pavlou and Dexter, 1979). During the operation of the proposed project over 300,000 cubic asters of sod inant containing approximately 50,000 kg of KBs will be reserved froa the river (hPI, 1981). Associated with the procedures for removing and ' encapsulating those contaeiaeced sediments is the loss of KBs from two short-term sources: the resuspended sedimencs in the dredge area and the return flow and leachate from the containment site. Although the mechanises that govern the flux and subsequent loss of PCXs are not well understood, various predictions have bean made concerning the impact of these sources on the elevation of PCX concentrations in the environment. Lessee of PC3a to the ufsoo liver near the dredge area ara expected to increase ambient levels by 0.2 ug/1 with hydraulic dredging procedures and 0.A ug/1 with clamshell dredging (HPI, 1980). PCS loss in the containment site return flow can be controlled by treatment procedures designed for the project (HTSKC, 1981a). With hydraulic dredging it ia predicted that 70 kg of PCSa vill be lost in the return flow, resulting in an increase of 0.1 ug/1 PCB over aabianc .concentrations. Whan clamshell dredging is employed, discharge end KB lose will depend upon whether ehe return flow is racyclad. Whereat the loss of PCBs to surface waters ia unavoidable during the operation of the Project, the potential for groundwater concauination ia minimal. Since certain features of the containment aits and surrounding area act to retard the outward migration of tutor end because PCB molecules strongly adhere to soil particles, it is expected that PCBs could reach any groundwater areas only after an axcranaly long period of cima (MPI, 1980). Water Quality Considerations Thera era a rnsaber of Federal and Scats regulations which apply to concerns addressed ia this portion of the nonitoring program. An ambient surface water quality criterion of 0.001 ug/1 has been tec by the OSgPA for the protection of aquatic life (40 CTR, Parc 129). New Tork Scats has adopted e II-3 HONS 009584 rCI froundwictr acsndsrd of 0.1 ug/l (i HTCU 703). ta 1973, NTSDEC adopt** in U dredging- regulation*, a guidelino laval for PCS* of 0.3 ug/l based on cha analytical detection level ae that tina. Tha Naw York Seaca Pollution Discharga Elimination Systam (SPDIS), promulgated undar cha Federal Clean Water Act and RTS Environmental Consarvation Law, establishes affluanc limits for point sources such at tha projact containment sit*. Spaeific affluanc liaicationa and monitoring requirements for PCS*, suspended solid*, and several natals hava baan astabliahad for cha soncainaanc sict diseharga (Tabla II-l). Stata ragulations for aolid waata aanagaaanc faeiliciaa (RTCSi Parc 360) includa monitoring requirements for laachaca and groundvacara. although chara ara currently no Padaral or Stata drinking uacar standard a for PCSa, tha RTS Dapaztaant of Baalth ha* iaauad a racotnandad guidalina laval of 1.0 ug/l for drinking uacar. Tha naaraac public drinking uacar supply chac draw* from cha Hudson livar ia at Hatarford, approximately kg km downstream or thru* daya travel tin* ac an average aisaaor flow of S3 m^/s. Assessment of River Hocovary Analyses of Budaon livar uatar aaaplaa collected over a rang* of river diacharga rata* indicate that cha distribution of PCBa bacuaan cha diaaolvad and adaorbod phaaaa ia flow-dapondant. At low flaw, PCS* reside primarily in cha aqueous phaaa and chair eoneoncration* ara inversely proportional to flow, uharaaa at high flow thoy are aerbad to particulate aactar chat ia arodad or acourod fran the river bad (Turk, 1980). Thu*, flow dependency must b* recognised in cha daaign of tha river monitoring strategy, in calculating PCS transport to cha actuary, and in tha aaaaaaawnC of long can liver recovery. Tha project plans to- support aeudioa which will alucidsea cha dasorpeivo and eroatonal procaaaaa ralatad to tboae obaorvaciona (aaa Appendix B). Tha study sill anamina cha uatar/aadimont intaractions of PCBa using a variaty of fedson liver PCB-coutaminaced sediments and a range of flow ratas. This information, in addition to annual sediment and water away monitoring for savaral years followiag tha project, will support long-tan projoetions of PCS transport from tha Oppar Hudson. 11-4 HONS 009585 Tabla II-l. SFDES diaeharga parait affluant limitation* and monitoring raquiraaanta which apply to tha contaimant it# affluant during tba dradging oparaeions. Faramacar Diacharga limitation Daily Ay*. Daily Max. Monitoring iUquiramanc* (24-hr. comoaiet) Total FCHa Hydraulic dradging (12 USD) Claaahall dradging (l.i HBO) 20.0 ug/l 2.0 lba/day 100.0 ug/l 10.0 lb */day 0.26 1.3 Daily Swapandad aolid a Natal a: . Ar aanic Cadmiia Chromits Coppar . Uad Mareury Nickal Silvar line - 23.0 ag/1 -' - 0.1 ag/1 0.2 1.0 0.8 0.2 0.02 2.0 0.1 1.0 Daily Waakly Waakly Waakly Waakly Waakly Waakly Waakly Waakly Waakly ' II--5 HONS 009586 MONITORING STRATEGY Water-related monitoring aeeiviciaa which aceosmodate the evaluation of impacts of dredging on river biota aro addraaaad in cha biological monitoring prograi described in Sections IV and V. Certain water measurements are -squired, however, to both complement those programs and to provide information on ambient eoneentrationa and transport of PCSs in Che Hudson River water colvan, under various hydrological conditions, for the protection of drinking water supplies. uses Water Monitoring Protram The water monitoring activities provided by cha USGS will serve as the basic component in Che monitoring programs carried out prior to, during, and after cha dredging project (Table II-2). Between 200 and 400 wacer samples will be collected throughout each water year at five stations in cha Upper Hudson River for PCB and suspended sediment analyses. Sampling periods will be selected to Cover high water events, aumur low flows, and ocher critical periods during the dredging season. Three Co five high wacer events, defined by flews of 23,000-30,000 cfs at Waterford and proportionally less at upstream stations, will be covered. The number of samples par event will vary, with up to a maxima maker of six sessples collected for the peak spring flood event. During low flows, samples collected from the canal and channel at Rogers tslassd will be flow-proporcionally composited, but during high water events separata samples will be collected. During 19B2 intensive sasspling will be performed at Stillwater, with 12 samples taken over cha hydrograph during one high water event to examine the relationship between PCS concentration and river flow. An additional 12 samples will be collected across cha river at or near peak discharge to determine whether lateral homogeneity exists during high water. Suspended sediment and conductance will be measured for each of these samples. For PCB analysis, three subsets of four samples each will be flow-proporcionally composited. - During Che dredging period, extensive sampling will be conducted at Stillwater to measure lateral hoaagenaicy during two different flow regimes. Samples will be collected across cha river at cha onsac of dredging and, later in the season, whan flows have decreased. ' As pert of baseline monitoring, 20 watsr saa^laa collected during spring high flow and sumar low flow at Stillwater will be analyzed for both total snd dissolved PCBa. These data will be used to examine cha contributions of sediment desorption and erosion as processes related to PCB transport in the water column. . River discharge will be determined each year, on a continuous basis, sc established 0SG3 water-stage recorders at Ft. Edward, Scillwscer, and Waterford and, when samples are collected, with a wire-weight gage sc Schulylerville. Semples will be collected daily for suspended sediment analysis at Stillwater and Waterford'.' II-4 HONS 009587 *' 2 4: Table II- . Annual i^llii| MCI for IMCS Mm Biver PCI aCudiee. Taafc liver di(charge Ciena Pal la - logera Ialand - Ft. Bdward Continuoua Scbuylerville For every PCB analyaia Stillwater Continuous Continuoua Suspendad sedisents For every rci For avery PCB aaatyaia - For every PCI analysis Daily * 12 per one Daily analyeia . event PCB laapling and analyses: Low and base flow High flow event a 5 eaaplaa Up to A aanptaa for 3-5 event a 25-30 aaaplea (canal * channal , coapoaita) f Up to 1 eaaplaa for J-i event a Assess Variability over one event Diaaolved and total Sanpling quality control - 1 - Duplicetes -- ~- 25-30 aanplca 25-10 aaaplaa 25-30 aeoplea Up to 6 aaaplea for 3-5 events Up to 6 saople* for 3-5 event s - 12 sasiplea Up to 6 aaaplea for 3-5 svents - - 20 aaaplea - - 12 eaaplea (1 analyaea) for oae event - 10 ssaptea - I I HONS 0 0 9 5 8 8 A cooperative monitoring program between cb* USCS and HTSDCC will eontinuo it th* IIM Laval of intensity far 4 minimum of fiv* years sftar cha dradging pro j act eo *id eh* uns*Mnt of rivar response Co dradging. Rivet Seudiaa Purina Dradsini Th* immediate and long-Cana river monitoring providad by eh* OSCS prograa will ba supplemented during cha dradging yaar with oehar water aeudiaa Tabla II-3). In an intensive atudy of vatar quality naar eh* dradg* araa, wacar tamplaa will b* eollaeead at various points upstram and downatraaa from Cha dradg* plus*. An aetaape will ba aad* to corralae* sampling loeaciona with cbea* uaad in eh* PCS bioaceumulacion aonieoring program* (so* Saeeiona 17 and 7). Savarsl dya aeudiaa, eondueead during eh* suaaar prior eo dradging to dafina nixing proeaaaas, will aid eh* positioning of waear and bioaeeuaulaeion aonieoring seat ion*. PCS transport eo Cha aacuary during dradging will b* assessed using PCS and auspandad tadinane data obtained fraa waear saaplat eollaeead ae eha Troy Daa. Sample* will ba eollaeead by HT3DEC for 20 days after dradging comneii assd on a weakly basis thereafter if PCS levels do noc axcaad 1.0 ug/l. If eoaeaneraeiona eonsiseanely axeaad that level, a sampling prograa will b* initiated in eha estuary which will inetud* aonieoring ae publie drinking waear supplies drawing from eha Hudson Rivar (MPI, 1981). Potable Water Supplies Primary consideration for eh* iapaet of cha.project on human healeh involves iaeeasiv* aonieoring at th* Waterford publie waear supply. Finishnd water will be aonieored by HTSSEC for the first 20 days of dradging aad ones every other wank thereafter if levels do not axeaad the HT3DOH-rsennaanled guideline level of 1.0 ug/l. If that laval la exceeded, an axiseing connection to tbo water supply at Troy, Hew Tork, will be used for Vatarford driokiog wetar. .' . All pocabl* water supply wall* within 800 a*ears of the eoneainaanc sics will b* aaaplad by HTSSCC twiea per year prior to, during, and for fivo yaar* after the project. Sample* will ba analysed for PCS* and aeeals (irsanie, - cadmium, chromium, eopper, load, mercury, nickel, silver, and zinc). If chase well* become contaminated, ltTSDCC will supply bottlad drinking wacar and carbon filters for faucets to households that depend upon these source*. Containment Sit* Monitoring Activities Monitoring at th* eoncainmnne sita is partially dictatad by various Scats aad federal permit raquiramnnca. Th* acquired data vill ba useful in the assessment of ecological consequences and effectiveness of the reclamation methods. 3PCU permit monitoring requirmaents for cha eoflfainmanc sic* are listed in Table II-l. Open closure of tba tie*, monitoring is required for netala an a monthly basis and PCS* and auspandad solid* on a weakly baais, but Cha discharge limitations remain th* same. . II-8 HONS 009589 i, Table 11~3. Sampling aitrii for MYSDCC mtr studies during tlw ii-aontk dredging Mason. An aUriak (*) Indicates that eaaipllng will ha continued aftar dredging caaaaa. Stapling Location Hudson River in relation to dredge pluaie Hudaon River at Troy Han Containment eite lagoon *Contaifuaent site return flow ^Containment aite ' leachate ^Groundwater monitoring welte Finiahad drinking water et Waterford Private walla within (00 atare of coatainaenc aite Purpose Analyaia Assess PCI losses from dredging PCR Aeaeee PCI Craneport to actuary peg Suspended aadinant Assess PCI voletil leal ion Assess PCI lose to Rivar: RPDK8 raquireawnt PCI PCR 8uependad aadinant Hate!a Aeaeee 'PCI loaa iron lagoona PCI of PCI through eoll PCI Protection of drink' ing water aupply PCI Protection of drinking water auppliae PCI Hat el a . Frequency As required Mo. Samples As required Daily for 20 daye then weekly M 69 69 Daily for 30 days then weekly Daily Daily Weakly Monthly 69 no ! no 26 6 Four times per year Daily for 30 days then every two weeka Once per year M , 16 1 65 35 35 HONS 0 0 9 5 9 0 i Every three months, beginning ac Itaic on* month after the construction of Cha wall-monitoring network, groundwater at che containment lies will ba monitorad for PCBs and natals, as wall as vacar surface aitvacion. A cluattr of threa walls will ba constructed at sis locations around tha lagoon arts to permit co Use cion of groundwater from depths of 12, 22 and 32 feat. The daepast wall will penetrate cha rock substrata by ac lease IQ feat. Ground>acar monitoring requirements are specified in cha WTS Parc 360 permit, which is issued for the construction and operation of a solid asce disposal facility. This permit also requires monthly measurements of cha level, trans ferred voltae, and PCS concentration of leachate In standpipes at the containment site. Initially, samples of water from the containment site lagoon will be collected daily in order co assess the fluctuations in dissolved PCBs. Since cha lagoon syacem retention time is several weeks, the frequency of sampling will be reduced after trends in dissolved PCBa are determined. These data will be used to anticipate critical rates of PCB flux from cha containment lagoons (see Section I). If excessive dissolved PCB concentrations are approached during adverse meteorological conditions, the influent and flow throughout the containment and treatment areas will be temporarily ceased, and all units will be treated with a slurry solution of powdered activated carbon. 11-10 HONS 009591 . METHODOLOGY 7laid ind Semolina Procedural ibid son River watar samples will routinely be collected us in* I1SGS depth-intagrating sampling equipment fitted with * one-liter bottle. Equipment used far collecting samples for PCX analysis will ba .thoroughly cleaned with banana initially and will ba rinsad with river watar prior to aaeh sollaetion. Samples will ba eollactad from bridgas naar tba eneer-of-flow or from a boat 1 at pradatarainad locations. Vatar samples eollactad ae tha containment site antail various equipment and procedural requirements depending upon tha area and purpose for monitoring, (ffluane from tha treatment facility will ba composited over 24 hours by an automatie sampler. The sample will ba scored in glass and kept eool during tha compositing period. Discharge from tha treatment facility will ba measured using a 7-notch weir and seaga recorder. Water samples will ba obtained from the 11 walls in tha groundwater wall monitoring network with a Teflon-coated bailor or by pumping through Lanan or Taflon tubing. Composited watar samples will ba taken from the lagoon either by traversing tha area with a boat or by periodic collections at the lagoon ouclac. . - All samples procured for PCX analysis will ba eollactad and stored in solvent-rinsad glass bottles. STSDEC specifies haxane and acecone rinsas, whereas USGS routinely aasploye hexane followed by oven-drying at 400*C. Battles will ba capped in tha field with Teflon-lined lids, and an effort will be made to minimise air spaea baewaan the surface of tha sample and tha lid. .Samples taken for tha purpose of determining dissolved and total PCBa will ba filtered through a 0.43 u silver oxide membrane filter immediately following collection. loccloa used for collecting samples for suspended sediment analysis will nee require a solvent rinse, and STSDEC samples may be transferred to plaacie .containers for transport and storage. Watar samples for mocals da terminations will ho eollactad in detergent and acid-washed glass boctlas rinsed wich deionised water. Immediately after collection, tho pH of these samples will be ad justad to laaa than two with 8H HHO3 to prevent precipitation of dissolved metals (SPA, 1979). All sMple containers will be appropriately labelled at tha time of collection and {mediately placed on iea for transport to tha laboratory where samples will be stored at 0-4'C until extraction and analysis. A sample sntmission form will accompany all samples sent to tho laboratory, and dnplieatos will ba retained by tha sample collector. Details regarding cha information required in both tho NTSDEC and USGS forma era provided in tha project's QA/QC plan (HTSDEC 1981b). Rivar discharge is determined from stage height measurements at four USCS Hudson Eiver stations (Buchansn and Somers, 1978). Stage height'ae Schuylarville is determined by wire-weight measurement of the distance from ridge to watar surface. USGS gaging stations ae Ft. Edward, Stillwater, and 11-11 HONS 009592 Waterford provide a eontinuoua record of river acage. Stagt-diaeharge relatiouahipe eatabliahad for theaa ataciona art recheeked and updated by direct aaaauremanc aavaral cini aaeh year. To aaaaaa river nixing for petitioning of vacar and bioaeeumulation nonicorlng ataciona, aavaral dya craear atudiea will b performed during the naaaar pracading dradging. On aavaral oeeaaiona, Rhedamine UT fluoraacanc dya vill be ineroduead eo diffarane araaa in cha Thompaon I aland Pool. The dya'a transport will be nonitorad uaing a Turnar Modal III fluorooaear on tha adapting vaaaal until cha dya ia latarally vail nixad ovr cha rivar. Analytical Proeaduraa PCBa: Wacar aaaplaa ara astraecad with 13 parcanc machylana ehlorida in haxana. Tha driad and eoncantratad axtraee ia analyxad by gaa chromatography. Tha PCS project lab will follow proeaduraa ouelinad in cha tfYSDOH Handbook of Analytical Mathoda (tfTSDQR, 1990) with Cha exception chat a Hall detector will ba employed. Daca will ba raported aa ug/l of Aroclora 1016, 1242, 1254, and 12(0. Tha OSCS Aclanca laboratory uaaa electron capeure equipped gaa chromato graphy and reporta total PCSa. Succeeded aadinane a: Tha PCS project lab will maaaura boch cocal and filerabla raaiduaa dried at 103 -103*0, according to Machoda 209A and Z09C of Standard Mathoda for tha Examinetion of Water and Wastewater (1980). 0S6S aamplaa will ba aanc to tha 09GS obia diacricc laboratory for auapended aadimant analyaia idtieh ia parformad by filtering each aample and drying cha residua at 103 -105*C. Sixa analyaia will ba parformad on sauplea collected during parioda of high flew (OSCS, 1972). Hacala: Samplaa collacead for matala analyaaa will ba aanc to Che HT390B laboraeoriea. Analyaia ia performed by atonic abaorpeion apoceroacopy according to proeaduraa daacribad ia 03IPA Mathoda for Chemical Analyaia of Water and Wactat (SPA. 1979). `Quality Aaauranca . Quality aaauranca plana for cha above programa appear in Sectiona Mo. I, Quality Aaauranca Plan for (Juiced States Geological Survey, and No. 2, Quality Aaauranca Plan for PCS Seelauation laboratory (NTSOEC, 1981b). 11-12 MOWS 009593 DATA ANALYSIS As indicated by the objectives of the water non!coring program, water juality data vill ba uaad for savaral distinct purposes including: aaauranea abac himan haaleh standards ara baing aac; controlling treatment procaaaas ae Cha containment sics; seraaning for groundvatar contamination; aaaaaamant of dosmatraam concainmant losses and -proeasaas associacad with dradgiag; and aaaaaamant of long-term changes in dosmatraam PCS export from tba Upper Budaon attributable to tba project. Tor. eontrol of proeasaas at tba containment sita in addition to control at cha dredge, in response to PCS concentrations in tha river water, relatively rapid sample and data analyses will ba required. Sasvy metals and PCS data from tha Haterford Treatment Plant, wall water from private rasidaneas, and cha Hudson Sivar at Troy will ba made available to local and Stats health officials. Initially, this data will ba aasasaad for its significance in relation Co the appropriate standards. If a result is naar or axeaads a , standard, natural variability and sampling and analytical errors in addition to mechanisms producing unacceptable water quality contributing to tba incident vill ba considered. Tha weight given any one of thasa factors prior to initiating appropriate action will ba a function of tha human health/ecological implications of Cha result. Tha appropriate action to ba cakan may include any combination of resampling, reanalysis of reserve sample, and, if cha standards ara dearly being axcaadad, tba implementation of remedial measures by tba project. Mean daily discharge from cha concainmant sits will be obtained from the site aanagar. Tha produce of naan daily discharge and the 2A hr composite PCS concentrations will ba uaad for comparison to 3PDES discharge limits. For depended solids and metals, tha measured concentrations will be compared directly against 37DES limits. If the flux of PCS or concantrscion of ocher SPBgJ-regulated constituents exceed the defined limits, the treatment process will be altered to bring the discharge within limits. Special studies of heavy natals and PCS from tha dredge site will ba analysed using s mass balance sebame previously applied to Hudson givar dredging by grown (1981). This approach determines sediment and PCh sinking rates in addition to PCS and metals transformation ratea uaing daca collected over a river reach upetraam and dovnstrea of Cha dredge. Adame and Darby (1980) have applied a mixing model to predict soluble contaminant concencratione in hydraulic dredging process water. The model nredictions were based upon dilution of sediment pore water with process water, to predictions ware than used to assess whether contaminant precipitation or 11-13 MOMS 009594 :i.um ieom -.eo^eanes was occurring. The modal will ba modified Co meluda explicit consideration of eranatarmac ion processes and usad co asaasa procaaaaa associated with hydraulit dredging. Onca validated, eha modal could ba aaad in Cbm avant chac Curehar process concroi is naadad eo comply with SFDCS or ochar limitl. The effect of varying hydraulic dredging paramacara on pradiccad ' contaminant concantrationa in eha concainmanc aica could ba uaad co adjust .redging procaduraa if naadad. . Tha OSCS data sac will ba amployad in eha calculation of annual ?CS sapor5. Particular aaphasia will ba given to loaaaa during high flow awanta. da affort will ba mada to accoune for variability in PCS and aadiaant eonaancraciona ovar avant hydrograpba and during baaa flow parioda. riowconcencr scion ralaeionahipa, davalopad for non-avant flows would ba uaad with flow-duration analysis for loading calculations. Trends in annual loading in addition co annual lew flow - PCS concentration ralaeionahipa will ba uaad to assess che response of eha river eo dredging. This analysis will ba supplemented by data from an investigation of bad sediment erosion and PCS desorption to projacc the long term transport of PCS from eha Upper Hudson. A request for proposals defining eha need and objactivas for such an invescigrtion is provided as Appendix B. II-IA HONS 009595 references Uai, 9.D. and D.A. Darby. 1980. A dilution - mixing nodal dasignad for dradgad sediments in freshwater ayicau. In: R.A. Baker [ad.], , Contaminants and Sediments, pp. 373-392. Ann Arbor Scianea Publishers, Ann Arbor, HI. . Irovn, M.P. 1981. PCS Desporption from River Sad inanes Suapandad During Dradging - An Analytical Framework. Xaehnieal papar Ho. 63. Haw Tork Scata Department of Environmental Conservation, Albany, NT. Suebanan, T.J. and W.P. Soaara. 1978. Scaga Haaaurasant of Caging Stations. Techniques of Ueesr-Rasourcas Investigations of the Uni tad Scacas Gaological Survey, Book 3, Chapear A7. D.S. Cov. Printing Offiea, Hashingeon, D.C. altar, M.T. and H.Z. Johnson. 1977. A nodal system eo study tha dasorpeion and biological availability of PCS in hydrosoila. In: F.L. Hayar and J.L. Bans link [ads.], pp. 178-193. ASTM ST? 634. latling, L., E. Born, and J. Tofflsmire. 1978. Smeary of Hudson Rivar PCS Study larules. Tachnical Papar Ho. 31. Kav Tork Stata Department of Esvirotanntal Conservation, Albany, HT. Eaaaga, E.E. and C.A.I. Goring. 1980. Kalacionsbip bacuaan water solubility, soil sorption, oceanol-waear partitioning, and eoncaneraeion of chemicals in biota. In: J.6. Eaton, P.R. Parrish, and A.C. Handricka [ads.]. Aquatic Toxicology, pp. 78-113. ASU ST? 707. Halcola Pirnia, Inc. 1980. PCS Hoc Spot Dradging Program, Upper Hudson livor, am Tork. Draft Enviroonantal Ixpact Seacaaant. Prepared for Hao Tork Stata Dapartaanc of Enviroonantal Consarvation, Albany, (IT. an Tork Stata Dapartaanc of Environoancal Consarvation. 1981a. Xasponsa eo tha Executive Suonary of Draft Environoancal Ixpact Stacewene, Nan Tork State 'Dapartaanc of Enviroimwntal Conaarvacion, Albany, NT. Ian Tork Seats Dapartaanc of Environaaneal Consarvation. 1981b. Quality Assurance Plan for the Hudson liver PCI RaeIsaacion Project. Ran Tork Seaee Dapartaanc of Environaaneal Conaarvacion, Albany, NT. an Tork Seats Dapartaanc of Health. 1980. Analytical Handbook, NTSDOS, Division of Laboratories and Research ,-hlbany, NT. O'Connor, D.J. and J.P. Connolly. 1980. Tha affect of eoncaneraeion of adsorbing solids on eha partition coefficient. Hater Rasaareh 14:1317-1723. Paris, D.F., H.C. Scaan, and G.L. Baugham. 1978. Role of physico-cheaical prepareias of Aroclors 1016 and 1234 in dacarxining chair fata and trans port in aquatic environments. Chamosphere 4:319-323. HONS 009596 11-13 Pavlou, S.P. nd R.N. Baxter. 1979. Distribution of PCBs in estuarine ecosyecaas. Tatting the concept at equilibria partitioning in cha oarina environment. Environ. Sei. and Taehnel. 13:65-71. Porterfield, 5. 1972. Computation at Fluvial-Sediment Discharge. Techniques at Water Resources Invaatigaeiona at cha Onited Scaeaa Caological Survey, look 3, Chapcar C3. C.S. Gov. Printing Office, Washington, D.C. . Turk, J.T. 1980. Application of Hudson River Baain PCB eranaport atudiaa. In: R.A. Baker [ad.], Contaminants and Sediments, Vol. 1, Ann Arbor Bcianea, Ann Arbor, Ml. (J.S. Environmental Protaction Agency. 1981. Craft Environaancal Impact Stacaaant on cba Hudson Rivar PCB RaelaBacion Demonstration Project. USEPA, Ragion 2, Haw fork, NT. O.S. Environaancal Protection Agency. 1979. Maehdda for Chaaical Analysis of ' Water and Waste a. EPA-600-4-79-020. Wildijh, D.J., C.D. Metcalf, 3.M. Akagi, and S.W. McLaasa. 1980. Plus of Aroclor 1254 batwaan aatuarina sediments and vatar. Bull. Env. Contra, and Tox. 24:20-26. 11-16 MONS 009597 SECTION III. PCSS IN TERRESTRIAL VECITATION GROWING NEAR THE SEDIMENT CONTAINMENT SITS Bureau of Hater Research , Division of Veter Nov York State Departaant of Environmental Conservation HONS 009598 umoDDcrxoN Tha sica selected for the encapsulation of Hudson Hivar PCS-eoncaminaced sediments is within an sgrieultural aria primarily davocsd co dairy faming. Within a 16-km radius of eha sica chars exist'ISO moderately sizad, fsmily- wnad, actia farms. Much of cha farmland is usad to grow crops, such as eom, alfalfa, clover, and oehar foraga plants, co faad dairy covs. Farmers in cha aras have axprassad eonearn chat chair eropa and milk might bacoma contaminated with PCBs in axcass of fadaral limits and, tharafora, unfit for faad or sala. Tha D.S. Food and Drug Administration (FDA) has established tolaranca loralI of 0.2 ug/g in faad for food-producing animals and 1.5 ug/g (fat basis) for milk and dairy products (Fad. Rag., 4A, 38330, Juno 29, 1929). Sines it is possible that soma foraga crops grown in eha vieinicy of cha concainmanc sica will bacoma contaminated to a level beyond the FDA limit (Buckley, 1981), a comprehensive plane monitoring progra is required. Tha monitoring data will be uaad in conjunction with a cosvensatieu plan for affacead farmers in eha vicinity of cha concainmanc sica (1TTSDEC, 1982). As part of this program, HTSSKC will acquire a temporary easement within a one-half mils radius of the outer limits of sica construction. Plants growing within tha easamene area will not be usad for animal consimption, and farmers will be compensated for loss of chat land for growing crops. Compensation is also required for farmers suffering economic lossas in the avenc chat erops growing outside cha easamene area baeoma contaminated beyond tha 0.2 ppm FDA limit. Any farm or garden craps which bacoma PCI-contaminated as a result of tha project will ba removed by R3DIC and placed on cha eastern portion of tha containment sits. Tha compensation plan sad contingency measures related to potential contamination of agricultural resources are strongly reliant upon accurate and timely analysis of PCBs in vegetation^ - Tha plant monitoring program has the fallowing objectives: establish background or pradradging PCS levels in terrestrial plants growing in tha area of the proposed containment sits; assist in prediction of PCS levels in forage crops growing near cha containment site during cha operation of cha project; docaent changes in air and plant PCS levels during cha operation of tha project; and doctsMnt air and plant PCS levels aftar the containment sice is capped. III-l MOMS 009599 BACKGROUND Sine* 1980, the Boye* Thompson Institute for Plane Jiitarch hat conducted studies an eh* accisulacion of PCS* by several *p*ci*s of terrestrial plane*. Background l*v*l* of foliar ooneaninaeion hav* been d*c*rain*o for IS *pei** including goldenrod (Solidato nemoralis I..), staghorn sumac (Rhu* typhinia L.). ah it* pin* (Pinu* strohus L.), field com (2aa mays L.). and rad clover (Trifolium prsesns* L.). Background levels war* found eo b* sp*ci**-d*p*nd*nc, with een-iold differences in PCS concentration levels observed within specie* growing at a given sic*. For example, foliar PCS concentrations ranged from 0.03 ppm in . _strobu to 0.32 ppm in S_. nemoreiis (Buckley, 1982). To reere the specie* Tfface on bioaccusmslaeien and to accommodate expression of PCS levels on a ccninn basis, a "multiples of background level" (MSI) concepe was developed (Buckley, 1980). All species were shown eo provide the same MSL at a given tie* with a standard deviation below ^ 2} percent (Buckley, 1982). Plant bioaeeumulaeion studies hav* demonstrated that PCS* art not readily transported through roots and shoots and that the major route of uptake is through eh* above ground plane pares (Buckley, 1982; Strak^^., 1981; Pal at el., 1980; Weber and Mrozak, 1979; Iwata at al.. 1974). Further, PCS concentration* in plants were shown co be directly related eo ambient air PCS concentrations. The relationship* between foliar and atmospheric PCS levels were determined for several plane species along a transact from a known source of PCS* (Buckley, 1980). These relationships were used co predict plant eonceneraeions at various known atmospheric PCS levels (see page 1-3). Ambient aemospheric PCS concentrations in eh* area of eh* proposed PCS--contaminated sediment encapsulation siea are currently around 0.003 ug/m3 (Buckley, 1981). During the operation of Che project, levels are expected to rise eo 0.3 ug/*3 ae the cootaiitnt siea and 0.2 ug/m^ in areas adjacent Co eh* sit* (see page Z-3). The capability doe* not exise at this time to accurately predict eh* areal extent of atmospheric dispersion of PCSa from eh* concaiamane site. Buckley (1980) has detected elevated foliar PCS concentrations up to 700 m from known PCS dtasp sites. Considering the .uncertainty involved in the estimation of PCS loss and dispersion from eh* containment area, a flexible and responsive monitoring program will be impl amented eo assess ehe degree and extant of PCS accumulation in planes during the operation of ehe project. m-2 HONS 009600 MOBITOailW STJUTSST Background monitoring has been performed for cue years on agricultural crop* growing within a 9 km* araa eancarad on cha encapsulation aiea. Sixteen sample location* war* datignaead by a l 'm x 1 km grid. This sampling atign will b* continued during cha operation of cha project, coordinating the ample collection schedule with times of crop harvest. Parennial and annual plants have been studied and aaintained in four replicate plots since 1981. These experimental plots are located 300 a south, 400 a southwest, 800 a northeast, and 1300 a southeast, of^cha encapsulation site. That* will b* used during cha operation of the project for coaparisen with background data and eaaaination of cha relationships between PCS* in air and plants which night be specific to the season during which dredging occurs. This study will include the measurement of PCS levels in the air at the experimental plots, additional plant collections will be node near the Lock 6 dan to determine any changes in plane PCB concentrations chat could be attributed to changes in the rate of PCB volatilisation from the river during dredging. Samples will also ba collected at remnant deposits 3, 4, and 3 and at the Buoy 212, S413, and naw ttoreau sediment disposal areas. Per two years following cloture of the encapsulation ties, plants near the Lock 8 dam and grass samples from the site's cap will be collected and analyzed III-3 HONS 009601  8BTH0D0L0CT Standard procedures far plane residue analyses will b* used to collect, prepare, and analyse plane samples. In eha fiald, samples of plane eisaua will ba placad in appropriately laballad, PCS-fraa plaaeie bags and frocan on dry lea. Tha samples will archived ac -ZJ*C or transported to eha laboratory, accompanied by a aaapla aubaiaaion fora. In tha laboratory, aaaplas will ba weighed, lyophillzad, re-weighed and Soxhlee-axtractad using paerolaua athar. Tha extract will ba cleaned on a Florisil coluan and solvent-stripped. Analysis will ba parformod wieh a gas chromatograph equipped with an electroncapture dacaceor. Total PCIa will ba raporead. Approximately 250 plane aaaplas will ba collaeead for FCB analysis during eha oparaeion of eha projace. Air samples will ba collaeead by eha Florisil oaehod described in eha air aoaieoring prograa (saa paga 1-9). A daesceion limit of 0.10 eo 0.03 ng/e3 has baan daaonseraead using polyursehana foam as an adsorbent (Buckley, personal communication). Tha use of this adsorbene will ba compared wieh Florisil and used for ehis study if tha lower detection limit is required. Each sample will be an unispeciaea composite of a single plane pare from a ntaber of individuals and will ba collaeead in duplicate; one of chase will ba mibmitted far FCB analysis idtile eha ocher will be archived. Duplicaca analyses will be performed for ovary twenty samples. Other quality control measures, such as blanks^ standards, and spiked samples, will be ehe responsibility of ehe laboratory performing the analyses OlTSDEC, 1981). III-A MQNS 00960Z nrrxoDucnoN Several report* documenting the general decline of Hudson River fish KB concentrations have resulted fron the annual monitoring, since 1977, of Hud son liver fish for PCS contamination (Sloan, Armstrong and Hern 1980, Armstrong and Sloan 1980, Sloan and Armstrong 1981a and 1981b, Armstrong and Sloan 1981, Sloan 1981, Sloan 1982). These reports have indicated that the decrease of PCS concentrations has been due to a reduction of Aroclor 1016 and, to a lesser extent, Aroclor 1221. Levels of Aroclor 1254 have declined very little, if at all. nonetheless, total PCS contamination remains high. For example, in the Lover Hudson River, 1981 samples of American eel averaged > 10 ppm; striped baas about 5 ppm; white catfish and white perch were also above 10 ppm on the average (HTSDEC 1981b). A spatial gradient is apparent with highest levels reported in the fish collected near the dominant sources at Ft. Edvard and Hudson Falls. However, the data also suggest that secondary, but lesser, sources exise in the lover portions of the Hudson River below the Troy dam. With the exeapeion of some migratory species, the trends in PCB contamination are, at presenc, moat satisfactorily expressed on a lipid-adjusted basis (i.e. og PCB/g lipid). Even in speeies where the association (correlation) between pa concentrations and percent lipid is not satisfactory, the same pattern of PCB trend is evident. PCB levels in the waeer column (Schroeder 1981) and invertebrates (Simpson 1981, O'Connor 1979) have alto decreaaad over this same period of time. The fish monitoring project described in this dociaant is a continuation of tha earlier work and addreaaaa fishery contamination issues related to the proposed drodging effort. The general objectives of tha fish monitoring project are to: sidentify temporal and spatial changes in levels of fish PCB concentrations as a consequence of abated PCB discharges and . determine changes in fish PCB concentrations resulting from PCB dredging activities in the Upper Hudson River. 17-1 HONS 009603 BACXCS0080 Contamination Characceriatica (com of cha lipophilic, hydrophobic, end peraiacenc characteristics, Kli, aa a elaaa of compound!, are widely distributed throughout eh* biota. They acewulece ia fatty tiaaua* uhoro the highait FC8 coneantrationa ara found (national Research Council 1979). Thia group of chemical a haa baon widaly uaad ia tavarsl induatrial and doaastie applicaeiona. Ita primary uaaga aa aa an inaulating rndiiat in alactrical equipment aueh aa transformers and eapaeitora (D.S. Environmental Protaction Agancy 1976a). Nil wara aanufacturad and uaad aa Aroclor mixtures. Soma of eba Aroclor mixtures ara more partiatant (Armstrong and Sloan 1981, Sloan and Araacrong 1981) and toxic (National Haaaarch Council 1979) chan othara. Sioconcancration factora can vary aeroaa two ordara of aagnicuda depending upon cha degree of chlorination of the biphanyl aolaeule (National Haaaarch Council 1979). In adaon Hirer tpaciaa, bioaccnulation appear a related to cha aaMunc of lipid aatarial in cha organisa. Thia relacionahip holde true boch intra- and ` iatarapacifieally. In other systems, such aa large lacuatrine bodiaa, cha incarapacific relacionahip ia atill evident but within cha speciea, variability, ia not adequately explained by lipid content (Araacrong and Sloan 1981, Sloan and Araacrong 1981)'. Toxicity axy be a function of ochar containanta aaaociatod with 70 euch aa polychlorinated dibenxofuran (PCDF) (litcan 1981; Brown 1980). jiatorical Data and Tranda la 197) and 1976, PCS coneantrationa ia the fiab of the Hudaou Kivar ware eatraaaly high (Heeling at al. 1978, Horn at al. 1976). Thia, in pare, raaulcad ia the sohaaquane order for cha General Electric planet at Ft.' Edward and ludaon Falla eo caaaa Cha diacharge of PCS to the Hud son River (New Terfc Papertaant Environaantal Conaarraeion 1976a and b). Aa a condition of cha 1976 . SettleaenC Agreaaane signed by'General Electric (GE) and the New Tork Scata tepertaant of Environaancal Conaarraeion (NTSDEC), funds vara aada srailabla to aonitor eoncaneraeiona of PCS ia fish collactad annually at various locations below the discharge. The active diacharge of PCSa froa the GE capacitor aaaufacturihg facilities was sharply curtailed in 1976 and earainaead in June, 1977. ' The Hudson River fiah-aonieariag project, fully iapleaantad in the spring of 1977, includes studias of PCS paecarna ia boch resident/frejhwacar and aigrant/aarina apaciaa. In Cha introduction, the general conclusions with respect to trends ia PCS fish coneantrationa were lilted, and aavaral reports ware cited dealing with the rasulcs of this projaet. Applicable fadaral and State Standards Due to cha tachnieal limit at ions associated with.PCS analyaaa, standards far consumption and anvironaantal concarna utilisa cocal 7CB coneantrationa rather than atcaapcing eo differentiate between PCS aixturaa (a.g. Aroclor 1016 araua Aroclor 1234) or specific eonganara. The U.S. Food and Drug Administra tion (1977) haa a csaporary colaranca level for fish in incertcaca coaaarea of IV-2 -- HONS 009604 3 ppm, and is considering a 2 ppu level as t final eoLsrsnes limit. A ruling - an Chit proposed change it expected sometime in 1982. To avoid confusion in issuing tdvica to sportsmen and fish-consumers, RTSOCC tod eha Hew Torlc Seact Dapareaane of Health (8T5D0H) follov cht eaadards established by cha 0.3. Food and Drug Administration. Tha laaa ttaadard it considered by HT3DEC in regulating centre ill fishing. Currantly, coanMrcial fishing is allowed in eba Hudson River axcape for American aai, white catfish, goldfish, carp, white parch tnd scripad bass. Recreational tnglars art advitad not to comuaa American aal (until ttcanely, potsataion of daarican aal was prohibited), whits catfish, vhita parch, gold fish and carp. HT3D0H tdvica on scripad bass and ochar spaeias is to rastriec consumption to ona aaal par waak. IfTSDOH advisas tgaiast con tuning any fish caught baevaan Ft. Edward tnd tha Troy dam (Aaalrod, 1982). Spaeific dacails on currant regulations regard ing tha pottatsioa and tala of Hudson River fish and salt appear in 6ITTCRR 11.1, 11.2, and 37.1(b). Economic Inpacts . Parker (1981), in an economic evaluation of tha impaee of PCS contamina tion in Indaott River fish, ralaead that in 1980 cha current eomearcial fishary waa valued at tors chan 31.7 million. Tha aajor species was American shad. A stmnmry on cha recreational fishery is presented in Table 17-1. Ha further stated that "with improvement of water quality, toxic substances (e.g. PCI) would bacoma a primary limiting factor in tha reestablishment of this wolti-million dollar industry." Parker's evaluation waa a follow-up to an earlier estimate by Sheppard (1978) wherein eha eomaareial fishery waa generating 3130,000 eo 3200,000 par year, sad eha raeraaeional sactor contributed 31.63 million. Tha largest adson River input to commercial and recreational fisheries was in eha marine 'district, estimated eo axcaad 320 million annually. Both evaluations concluded "that PO contamination poses a continuing threat Co tha development or reettablisbamnc of tha commercial and/or raeraaeional fisheries and that eha potential fisheries ara considerably larger than eha preaane fisheries. Table 17-1. Stmary of Pro sane and Future Effort and Aasociated Values of tha leeraacionsl Fisheries of eha Hudson River (Parker 1981). location Clans Palls to Troy Dam Present Furore Troy Dam to Peughkaapsia Present Future oughkeepsie to Sectary, Prssane Haw Tork City future Annual Angler-- Days (in 1000's) 0 23-30 8-10 56-112 . 70 840-1260 Annual Value (1981 dollars) 0 Dp CO 30.72 aillion Op CO 30.24 oillion Up CO 32.68 million Up CO 31.68 million Up CO 330.24 million 17-3 HONS 009605 HOHITOaZHG STBATJCY Tho objective* Car monitoring PCS uncainaiion > listed in the introduction. heiim of eh* specific concerns rl*t*d co dredging, eh* overall fi*h-aenieoriag serecegy involve* ewe dosigns. Fine, char* if eh* oneinoacion of eh* project is plc* fine* 1977, which jaei*fi*s eh* fine jbj active. ie will fife supplement eh* dradg* oenicoring abjective which involves uaing live, caged fish at aeveral locations eo determine if PCS is accumulating in eh* east organisas as a rasule of drtdging aceiviciaa. ' HOMITOHIHC DBS ICW I . tha baaic sampling locaciona and achadula for fish collection* (Tabl* IT-2) war* davalopad from 1977 co 1980. Th* apaci*s listed for eha various locations ara either potentially important racraacional and coaaarcial specisa or readily availabl* for eolleeeion. Th* sampling aicas war* selected in 1977 for *aaa of aceasa and eo rapraaanc diffaranc river reach** of varying contmaination. Continuity of ehoaa sieas has bean maintained over eha yaara. This tpaeias/location mix aaaea eha analytical requirements for eha non-dredging objacciv*. Adjustment* of sample sixes ar* datarminod from yaarto-yaar an eha standard errors associated with contaminant concentrations from a prior data year (a.g. 1981 raaulea ware used to update 1982 requirements). Tabl* IT-2 raflacts currant samp 1 a sizas required eo dasunaeraea, at eh* minimum, a 50 percane change in total PCS level*. In most case*, eha sample site* ar* adaquae* eo dociamne a 20 percent shift. In viaw of eha paraiatane nature of Aroclor 1254, monitoring beyond 1983 will be nacaaaary. However, eh* aehedul* la Tabl* IT-2 should be adequate through tha 1985 season with modification and updates as nacaaaary. Kadical .hamgea after 1985 are dependent upon an evaluation of eondieiou* at chat time. -- Methodology Collection and Preparation of Fish All fish specimens ar* collected by legional Staff of eha Bureau of Fisheries, Division of Fish and Wildlife, HT3SEC, uaing electro-shocking and gill-netting technique*. Whan applicable, atripmd basa, American shad and American eel ar* purchased from commercial fisherman. Collection goals ar* sometimes limited by availability due co woathor end other physical phenomena and ehasgea in apaciaa daneity and composition. To ninimiao eha possible complication of seasonal variation in. contaminant concentration, annual collections of given specie* at given locaciona ar* nada as else* a* possible to eha aasM cima of year <^_ two weeks). Fidi ere tagged with Monel jew cage, measured and weighed. Collection record* end continuity of evidence forms are maintained, beginning at eha time of collection (NTSDEC, 1981). Fish ara frosan whole in individual polyechylsne _.baga (quality control chacka ar* aaineeined on the plastic bage to ensure eboy ere not PCB-coneamineted). IV-4 HONS 009606 regulr i.oc.it ion iti, m mv>w| soesga i iim MllMrlaii IfjCIB_______ MWM J. commonKBS 0T tllKI sizes AVE (bAMCei an dsslrol reflect 1982 RVMflKS Above Feeder Daa Puapklnssad Puapklnaeed 73 73 3/20 3/20 -aga Id -agas 2d.3d.ld Stillwater Albany/Troy Yallow parch 20 brown bullhead 20 Largaaouth baas 20 Goldfish 20 Puapklnssad 73 Puapklnssad 73 Aawrlcsn aal ` . 1 brown bullhead 30 Milts parch 20 l/ll 6/10 ' l/ll 1/16 3/21 June 1/13 1/13 213(133-211) 231(178-315) 323(203-301) . 271(236-320) -aga Id -agas 2+,3+,Id- As avail. -lncldantal catch; lavals not y> dataralnsd In this spactas froa this 292(193-330) 197(152-277) ' - S -A I Alwlft/lluibick littering 30 ; Nak run As svall. -Species to bo aubal dependent upon cat* Puapklnssad .Puapklasaad 73 73 Carskill Milta parch 20 ' Largaaouth baas 20 Yallpw parch 20 Redbreast aunflah 20 Alewlfe ^tluaback barring 30 Kir{seen/ feugertlas Po.jhksepsie Alawiitt/bluttbttck 30 herring Striped ban American tl 23 30 3/20 3/20 -- 3/10 1/21 Paak run Peak ran Paak run July -- ' -age 1+ -ages 2d,3d,Id -- -at discretion of Regional peraonm. 201(113-261) 161(110-185) Aa avail. Aa avail. >157 as TL As avail. 'Species to be subai dependent upon cati -To be subalttad dep. ant upon catch - Nv3utgh HONS 009607 Puapklnssad Puapklnssad 73 | 73 i 3/20 3/20 - -aga Id -ages 21.3d,1+ Table IV-l.CmtliMl 1 orATIAN Pe.kaklll Tappan Zee Bridge SPECIES Striped bait AMrlcm eel African shad Strlpai baaa Uilta parch Aaertcan aal Malta catflah K'aahlngton Srldge Striped baaa . Aaertcan aal seam J5 10 10 21 21 JSIUi COLLECTION PATE - 2 HM SIZES m (BANGg) Paak run July Paak run Early run Lata run .. >417 aua TL Aa avail. Aa avail. >457 aa TL >4S7 aa TL 20 Pall . 10 July 10 -- Aa avail. Aa avail. Aa avail. 21 Early run >457 aa TL 2S Late nm > 417 aa TL 20 July Aa avail. REMARKS .. 15<W; 15^ -collect not lees then 3 later nor aora than 1 a -tlM of collection et <li cretlon of collector __ -collect not lent then 3 later nor aura than 1 m -reaponaunity; Dlvleloi. HONS 0 0 9 6 0 8 I fish from Regions 4 snd 3 are transported ia < fressn state to legion 3, Hew rtlu, tor Itonit until preparation tor shipment to Haxleton Bel tech, Madison, Ultconsin. Ac the time of preparation, fish srs thawed sad a standard fillet la prsparad (Appendix C), consisting of an aaeirt aids of aach fiab, with teslas removed, extending froa operculum to tail. la the eaaa of pwmpkinaaed, fish ars (round uhola. Skinned standard fillaca are prsparad for brown bullhead, whits catfish, Atlantic toacod and Aaarican aal. fillaca ara retailed, frosan, sad shipped via air freifhe, priority basis, to Iasiaton Aaleach, lac. idiero fillets ara (round and hoao(oniaad. The remaining carcasses ara kape in storasa at Raw fait* until results have bean submitted bp the analytical laboratory snd fCB analyses srs verified aeeaptahla. Analytical Methods . A dseailad aecount of analytical procedures by Baalaton Hal tech, lac. is found in Section Ho. 3 of the Quality Assurance flan for the Hudson liver fd Inclsaation Denonseraeion frojaec (lfYSDCC, 1981). Briefly, wei|bad portions of tba (round tissue are dried with anhydrous aodiuai sulfate snd extracted with three portions of pecroleua ether. An aliquot of the partially evaporated extract is placed on a Florisil eoltmn, standardised to elute FCB Aroclors. A sample of the elueed extract is than injected into e (as ehxoaatograph, fitted with aa electron-capture detector, and standardised using Aroclors 1221, 1242 and 1254 obtained froa the Monsanto Corporation. It is known that the Aroclor 1242 pattern obtained froa fish extract is indistinguishable froa chat produced by Aroclor 1016. Tha coloam packing is 3 percent OV-1. quantisation is dona by coapering salaceed peak heights or areas to ehoaa produced by tha respective Arealevs. Tha limit of detection is 0.1 ppa, wet basis, for each Aroclor. froa tha aaaa of raaidaa remaining after evaporation of a 5-nl portion of the original potroleia ether extract to dryness at 40*C, the percent by weight of tisane soluble ia petrolema ether is calculated. This latter percentage . A reality control protocol consists of two coaponanca. Periodic perforaanca saaplas to assess accuracy are analysed on a round-robin basis involving laalatan la1tech, Inc., other private contractors, sad several laboratories of HTSOBC and tha Row fork State Department of Health. In addition, Basletoo laltacb agrees that, for each 20 data points reported, three are of a control nature: ona reagent blank, ana duplicate analysis and a spiked recovery. ' Dsta_Analsiis With tha exception of American shad and striped bass (both larft-sixad, nlgrant specie#), the variability of FCB concentration within a species, regardless of age, can be expressed on a lipid-adjusted basis. Therefore, all FCB concentrations (total FCB and specific Aroclors) ara converted to a lipid basis by dividing aach analytical concentration ia xierograma of FCB per gram of wet tissue (ppm) by the fractional lipid content of.the tissue sample. Insulting concentrations are referred to as lipid-baaed, snd carry units of nicregrams of FCB par (ra of lipid. ,,QNS OO'609 jy-7 Temporal changes in total PCS and itJ Aroelers art calculated for given species and locations on a percentage baais from lipid-based PCS concentra tions. An effort will ba made to account (or variability or erand* in total PCS and tha diffarane Aroclors (or a given species, uaing empirical oathoda. Tranda in racanc (ash data have baan dascribad by a first-order decay nodal and iea associated half-lifa eoaeapC (Armstrong and Sloan 1980, 1981, Sloan and Araatrong 1981). - Half-lifs values obtained (ran thosa caleulationa do not describe tha ciaa required (or a 30 pareant PCS daelina to occur in a given (ish. Thosa calculated half-livaa redact tha time required (or a 30 pareant lipid-baaad daelina to ba observed in eoaparabla-populations of (ish o( given species and locations collected in di((arane years. Such half-lives therefore depend on both tha races o( PCS aeeiaulation as vail as tha rata of elimination and/or depuration. Responsible Parties Tha overall responsibility (or che project lies vith: Bonald Sloan, Ph.O. lesearch Scientist II . Bureau of Environmental Protection Hois fork State Department of Environmental Conservation 30 Wolf load, loom 326 Albany, Saw Tork 12233 Phono: 318-437-1769 Tbo collection coordinator ia: loberc Brandt aaaiaead by lobart Mitchell Bureau of Piahorias logion 3, Maw Tork Department of Environmental Conservation . 21 South Putt Corners lead ' Mew Palts, Haw Tork 12361 Phono: 914-233-3433 . Because of the workload associated with tha collections, an annual temporary technician (six aoncha aach year) ia required ae Haw Palts. Without this petition tha project cannot function. . Tha laboratory contact pur ten is: John Korean Baalaton laltech, Inc. 3301 Kinaaan Boulevard P.0. 7343 Madison, Wisconsin 33707 IV-8 HONS 009610 ^porting Schedule Bata win be reviewed, upon raeeipc, usually within three to six Wool's following submission of samples to tho laboratory. This will provide for timely, preliminary interpretation! to b usod by cho PCS project in tho asst appropriate aannor related to dredging secivitios. *11 docs will bo r--sriood end ine listed in cha c sport soriss "Toxic Sub tonesi in Fish and Wildlife'* tvary six months, Mora daeailad reports ora generated on on administrative daxand basis (orsl and written) and sciantifie documentation and interpretation are plaaaad during cha eoursa of tha project and at termination. MOHITOtlHC DgSICN XI Ivan aftar sarerol years of monitoring, cha role of PCa-eontaminstad eadisMnt and subsequent accumulation in fish flash i* uncertain (Sloan at al. 1981). For Cha Hudson River, secondary PCS sources are a consideration (Sloan and Arascrong 1981, Sargh and Paoplas 1977) which nay confound analytical ' results. . However, where known contaminated sediaenc is to ba removed, it it important to determine cha acctaulation potential for organisms exposed to dredged materials. Warner (1981) found in cha freshwacar clam (tliipclo canolanacua) little ewidanca suggesting chat dredging would contribute to increased PCS concentration. In a ralacad clam study conducted in cha Niagara liver, above and below a known chemical discharge, results ware inconclusive since all compounds tested ware below analytical detection limics tor tha nom-volatila tPA priority pollutants, including PCS (HTSDCC, unpublished data). Tbua, the choice of organise for study may ba critical. Sines Skaa at al. (1979) found significant accumulation occurring in aavoral apociaa of fiah bald in live-car over a 14-day exposure in tha Hudson liver, fiah of relatively homogenaua body conformation and siza may bo more appropriate to ascertain biological iaplieaciona of dredging. The following suggested study design will augsmnt tha invertebrate study proposed by Simpson (1982). . Tha atrstagy in Design II involves eba placement of live-ears containing even agod (ralacivaly homogeneous sixad) faehaad minnows (Piaaohalaa promelae) at varioma locations above and bolow the proposed area for dredging. Fntbead' minnows era suggest ad for in because tbay are readily available, widely used In .bioassay and ralaead tasting procedures and can accumulate high PCS Laval a (D.S. Invironmancal Protection agency 1976). Tabla IV-3 depicts tha numbers of fiah desired for exposure and PCI analysis (three Aroelors - 1221, 1016 and 1294) and the locations for cage placement. Dates of exposure listed in Table 19-3 related to tho projected dredging sehedulo (Scteict 1982) are subject to change since the dredging may not proceed as currently envisioned. This project should also ba conducted under Che same strategic regime cha year prior to dredging to: 1) provide adequate control data over different fled conditions and temperature strata; 2) allow time for development and modification of aquipmnne prior to dredging; and 3) asanas adequacy of experimental design (chemical and statistical analysas). ' 17-9 HONS 009611 Tabla 17-3. EXPOSURE AND LOCATION SCHEDCtE DESIGN II Ldeatlon Relation eo Raeurn Flow (aoorox.) Each axpoaura oartod tfumbsr Number Abort Fssdsr Don above Clan* Filli Ft. Edvard (dam ilea) Te. Millar balow dam bale* Sehuylarvilla above mouth Stockport Craak Uncoatamlnaead control 400 (200 aach caga) 2 eooposle. of 30 aac: Caneamlnaead control 400 (200 aach caga) 100 (SO ** caga)-10 eampoal: 3 km below (1 x 10) 400 (200 aach caga) 100 (joaaefc caga)-10 compotic 14 km balow (1 x 101) 400 (200 aach caga) 100 (SO aact caga)-10 eoapoaic 100 km balow (1 x 102) 400 (200 aach caga) 100 (]0aach caga)-10 compoatc Total flah over 7 tseposurs psrlad* 14000 29*0 analyxec 294 analyea* Pra-dredge axpeaur* Dredge ampoaura -at 1 ~' dredge axpoaure -lac 2 Dredge axpoaure -lae 3 Dredge axpoaure -aae A Dredge axpoaure -aae 3 Dredge axpoaure -*at 6 . . Data* (21 day expoaura) m "Hr May IS June 8 Juzia IS July 6 July 13 Auguat 3 August 10 Augus e 31 Sapeambar 7 Sapeambar 28 * Octobar 5 Octobar 26 Novambar 2 Novambar 23 17-10 HONS 009612 Methodology Ixpaaura and Preparation of Pish The cast minnows vill b purchased froa eoanareiai supplier (co ba arranged) co ensure choc chree-to-four month old Individuals (0.3-0.73 |a aaeh) will ha usad sc cha scare of aaeh of cha 21-day exposure periods. This langcb of exposure will ha suffieienc sines Sicaa ac al. (1979) found several ppa of PCX aeeuaulaead over a 14-day period in previously unexposed fish, Hie eases conducted in Che Hudson liver aad previous analysas of Hudson liver migrant epaaiee indieaee chat saveral hundred ppa on a lipid basis will occur in cha proposed 21-day exposure periods. Adaquacs lumbers (400 ae each locaeion) will be placed in Cha live-cars Co allow for soaa aorcaliey and increase the likelihood that 100 spaciaans will survive a given exposure locaeion period for subsequent analysis. The cast of ease organises is ona of Cha lesser expenses associated with this project and the benefit of ensuring svailsbiliey of sufficient nusbars for anlaysis cannot he owsranphasixad. Cowposieing 10 whole fish se each location/exposure conh lost ion will provide adaquacs Bass (> 3 ga) for PCS analysis, in Edition to reducing the variance to allow aors sanaieiva staeiseieal analyses. Tan analysas are projected far aaeh location ae aaeh axposura period (Table 3). 4b- Assistant Be search Scientist (S6-1A) will be hired for ona year to oversea the construction, deployment, testing, preparation and data interpretation of the project. The workload cannot ha atavned by existing staff. This parson will also sorva aa direct liaison with the dredging project to provide feedback for dredging operation aodification, if needed, another ajar responsibility will bo Cho tagging, preparation, and shipping of (dividual whole specimens to Haxleeoa laltech at the end of each exposure ported and ensuring that analytical turnaround turn is kept brief (two to threw weeks). - lack exposure setup will consist of a large live-ear in which two aaeller .cages will bo suspended, containing two raplieatas of 200 fish (400 total), guaponding Che mail units will aaaura that PCS aceralacion will occur aa a result of oacarials in cho water eolison rather chan through contact with eontaninaead sediaenc. The design of chase cages ia standard, aad detailed plana will be provided ac a later data. These types of cages ware used in sarliar-Hodson River work (Shoe at al. 1979). The tana general procedures related to Deaiga I data collection end chemical analysas are perciaanc to Design II axeape a detection liauc of 0.01 ppa ia spacifiad for each Aroclor. The ntmbers of fish usad for analysis reflect two considerscions: reduction of variance ia the data which provides far wore sensitive statistical analysas sod ensuring adequate bionass available for chenies! analyses. Data Analysis Tha basic design of cha overall decs analysis is'outlined in Tsbla IV-4. The analysis of variance nodal can be simplified co e 4 x 2 factor analysis for IV-11 M0NS 009613 Tabla 17-4 fd data arrangement foe cha three-factor design of analysis of variance (4x2x7); fixed effaces nodal; Nj.^ 3. Aroelors 1221, 1016 and 1234 aaalytad separately. J Laval of C Laval of B (Ixpoaure Parted) (Replicates) It 71 - 2t - A Laval of A (Exposure Location) Control 1 km 10 Vos 100 km tfcy 18 l '2 xm: *121. *211. *221. *111. *321. *417 * 421. June 13 ' 1 X,,,, X X X 112. 212. 312. . 412. 2XXX X 122. 222. 322. 422. July 13 1 x__ X X .X 113. 213. 313. 413. 2 *123. *223. *323. *423. August 10 l *114. *214. *314. *414. 2 X' X X X 124. 224. 324. 424. September 7 1XXX X iij: 213. 313. 413. 2 *123. *223. *323. *423. October 3 Hovaubar 2 l X* X X X. 116. 216. 316. 416. 2 *126. *226. *326. X 426. 1 i___ X x X 117. 217; 317. 417. 2XXX x 127. 227. 327. 427. 17-12 HONS 009614 Che results produced {ram each exposure period and permutations of exposure periods (A x 2 x C^). Thd unconcsainaced doncrol is not considered io cb analytical datifn because of the exceptionally low PCS eSneencracion* above Siena Falla (at or below the decoction limits in soar earlier analyses). Taae fiah placed above Siena Falla will be analyzed buc at reduced numbers (cue coapoaicas of 50 fish rather then IQ coaposices) . ' Statiatical analyses will be baaed on lipid-adjusted values. Hydrological ciae of travel ia a conaideracion in the analysis at the data. Approximately five days ciae of travel is required between the Ft. Hiller sice and cne Troy Baa (Shindel 1969). Another two days travel night be necessary to reach the Stockport Creek area. . kaeords on fish aortality will be oaincained and analyzed, buc eccunulacion, rather chan acuta toxic effeees, ia the prime conaideracion of this study. keaponaible Parties See pegs IV-8. leportint Schedule See pegs 17-9. IV-13 HONS 009615 Armstrong, R. and R. J. Sloan. 19(0. Trsnda In lavel* of sevazal known ehMical contaminant* in fish fro* Haw York seats waters. Bor- Environ. Protect., Oiv. Fish wildl., N.Y. aapt. Environ. Conserv. Tech. Bap. *0*2 77 p. Armstrong, R. and R. Sloan. 1961. PCB patterns in Hudson River fiah. I. Resident/freshwater spaeiaa. Pros. Hudson Rivar. Environ, soe., Byde Park, H.r. Axelrod, 0. March 15, 1982. Latter from 0. Axelrod, Cssmissiosar, Maw York Stata Department of Health, Albany, H.Y. to R. rlacks, Comissioner, Saw York Stata Oapartaant of Environmental Conaarvation, Albany, H.Y. Bergh, A. X. and R. S. Paoplaa. 1977. Distribution of polychlorinated biphenyls in a municipal wastewater eraataant plant and environs. Sci. Total Environ. Si 197-204. sewn, J. F., Jr. 1980. The tola of the scientific advisor in toxicant problem monitoring Coni, on wildlife To*-Ecology, S.Y. Oiap. Wild. Soe. Rochester, S p. Ratling, L. J., E. G. Bora and T. J. Tofflamire. 1978. Summary of Hudson Rivar PCS study result*. Tach. Rap. 51, Bar. Water Research, Maw York Stata Department of Environmental Conaarvation, Albany, n.Y. 38 p. Horn, E. G., 1. J. Ratling and T. J. Tofflamire. 1979. The problem of PCSa in the Hudson Rivas system. Ana. N.Y. Acad. Sci. 320: 591-809 Xdttan, S. 1981. PCI toxicity, a second lock. Division of Water, New York Department of Environmental Conaarvation. In-house report. 26 p. National Research Council. 1979. Polychlorinated Biphenyls. National Iradf of Sciancaa, Wash., O.C. 1982 p. Jtaw York Stata Oapartaant of Environmental Conservation. 1976a. Bearing testimony on PCB discharges, legal rile 12833. ~ New York Stata Department of Brrlxanmental Conservation. 1976b. Agreaamnt ' between General Electric and NYSDEC on PCB discharges, legal File 12833. New York state Department of Envlronnantal Conservation. 1981a. Section No. 3, Quality Assurance Plan for the Budaon River PCI Demonstration Reclamation Project. New York Stata Department of Environmental Conaarvation, Albany, B.Y. New York Stata Department of Environmental Conaarvation 1981b. Toxic Substances in Fish and Wildlife: May 1 to November 1, 1961, Volume 4, Number 2. Tech. Rap. 81-1, Diviaion of Fiah end Wildlife, n.y.s.d.E.C. Albany, 45 p. O'Connor, J. 1979. Personal eeemunicatlon. ' Parker, c. 1981. Pre-file testimony on New York Department of Environmental Conaarvation application to dredge PCB contaminated sediments from the Hudson River. October 21, 1981. . HONS 009616 ht-t Schroeder, a. 1381. luional oonramicatian. Sheppard, J.D. 1376. Valuation-of tho Hudson River Fishery Resourcss: past, Frasent and Future. Haw York Department of Environmental Consarvaticn, Albany, H.Y, SI p. Shindal, H. L. 1369. Tina of travel study, upper Hudson Sivar, Fort Edward, Haw Tosfc to Troy lock and daa, Cray, Haw York. Naw Yack Stata Conservation DeparBsent, Hatar Resources.Coonission. Siapaon, K. 1381. Personal conaunication. Slapaon, K. 1983. Parsonal ownnleatlon. . Skaa, J. C., H. A. Siaonin, H. J. Oaan, J. R. Colquhoun, J. J. Spagnoli and 5. D. Vaitb. 1979. lioaeeuanlation of Aroclor 1016 in Hudson Aivar fish. Mil. Environ. Contam. Toxicol. 22: 332-336. Sloan, R., R. Armstrong and E. Born. 1980. Daclininq lavala of PCS In Hudson Aivar fish: prospacts for recovery of tha fishary. Pishariaa Abatz., 36th H.z. Fish Hildl. Conf., EUaavilla, H.Y. p. 35-36. Sloan, R. 1981. Gming PCS convam-tnation to understand American aal lifa history. Ann. Mtq. H.Y. Qiap. Aa. Flsharias Soc., Harcy, H.Y. p. 6 Abstr. Sloan, R. J. and R. H. Armstrong. 1981a. Fiqhtinq for elaanar fish. Conaarvationiat. 35(5): 36-41. Sloan, R. and R. Armstrong. 1981b. PCS pattaxaa in Hudson Rivar fish. U. Migzant/merine spaeias. Proc. Hudson Rivar Environ, soc., Hyde Park, H.Y. Sloan, R. S. Jacklinq and J. McKinney. 1981. Osiag aquatic organisms to control tonic aubstaneaa - Hassan Lake, a caaa history. Flsharias Abate. 17th H.E. Fish Hildl. Conf., Virginia leach, vx. p. 22. Sloan, R. 19S2. An evaluation of chanical contaminants in Budaon Rivar fish. * Ann. Mtq. H.Y. Chap. An. Fiaharias Soc., Roaa, H.Y. p. 2. Abstr. -. U. S. Envlzcnaantal Protactiou Agency, Offlea of Toxic subataneaa. 1976a. PCRS in tba onitad States Industrial Use and Environmental Distribution. Criteria and standazda Divialon, o. s. Environmental Protection Agency, Washington, D.C. IPA 360/6-73-005. 334 p. 0. S. Bivlrcnaantal Protection Agency. 1976b. Quality Criteria for wetar. Office of Hater and Raaaxdoua Materials, 0. S. Snvironaantal protection Agency, Hash., D.C. DA 440/9-76-023 . 256 p. 0. S. Pood and Drug Administration. 1977. Polyehlorlaatad biphenyls (PCS'a). Fad. Rag. 42(63): 17487-17494. Hernar, M. >. 1981. Iha-use of a frashwetar mollusc (Elliptic comclanatsa) in biological monitoring pregraas. Toxic Subataneaa Control Act Cooparativa Agreement Mo. 3. Division of Kataz, Haw York Stata Oepareaant of Environmental Conservation. 47 p. rv-is HONS 009617 SECTION V. peas IB MACROINVERTEBRATES: LONG-TERM MONITORING WITH CADOISELIES AMD ARTIFICIAL SUBSTRATE RESIDUES AMO BIOACCT7MULATIOM MONITORING IS THE UPPER HUDSOM RIVER US ISC THE AQUATIC M1DCE (DIPTEHA: CHIROHOMIDAE) Canear for Laboracoria and Rasearch Ha Tork Scaca Dapareaane of Halath HONS 009618 ErraoDccTioH Tha results of an Environmental Impact Statement far the Hudson giver KB Baelana don Daonatracion Project (Malcolm Plrnia, Inc., 1980) indicate that aana rCBa will ba loat la tha vator coition luring cha dredging activities, ad that Cha abort-Cara adverse affacta will not significantly offsae cha long-cars reductions of PCS lavals la cha Hudson Hlver acoayataa. Ona of cha neat Important long--Cars objectives of tha project la to Improve cha fishary raaourea of cha river (Malcolm Plrnia, Inc., 1980).' tha biological nosieorlag program described In this document eonalata of alananca for assessing boeh abore-eaxo and l&ng-earm affacta of cha dredging program- Tha short-cars atndy la daaignad cs assaaa Co wbae aztane dredging altera cha ?CS eoncancratlon by dlarurbing eha eoneanlnaead aadlnasea. Although loaaaa eo cha water coluan daring dredging era not aspacted eo exceed 4 percent, monitoring will ba performed eo evaluate cha biological accumulation of POa loat eo eha river. Tha short-cars study will eonnsnea Just prior eo tha ansae of dradglag sad will condone for 18 months. Caged midge larvae (Diptera: Chlronowldaa) will ba placed above and below eha dredge alea at biweekly Intervals daring the dredging activities. Tha long-eaga study will ba a continuation of an existing monitoring program that has bean operational since 1977 (Slapeon, 1982). Mttlttiplata samples and eaddlafly larvae will ba eolleeead from IS and five aleaa respectively, Inc3,tiding locations oprtraaa and downstrass of eha areas to ba dredged. Tha long-cars effectiveness of eha project can ba datasmlnad by coppering post-dredging concentrations throughout cha river with predradglng levels. . The aaerniavmrcabrsta monitoring program has tha following objectives: measure lavals of PCSa aceamnlaead by orgauiams locaead naar cha dradga area to aammaa changes in PCS loadings to tha river biota daring dredging; and continue monitoring PCSs in mnldplata Maples (16 stations) and eaddlafly larvae (five stations) to asaaas subsequent chugse in PCS loadings resulting from cha dredging program. HONS 009619 V-l uasaouns Maeroiavertebrates are an Important component oi aquacic ecoayseaaa, occupying cha intermediate position, la terms of both size and anergy(law, baewaan microorganisms Qscteria, algae, and zooplankton) and vertsbrataa. Tha many kinds of freshwater macroinveTCebrataa include aquatic ' Inaacca and otbar artbropoda, snails, cl ana, and vaidous worn*. Baeanaa thay aza relatively issnobtle and ara sensitive to changes In water chmaiscry, they ara oftan need In biological monitoring program# to aaaass tha reladve health of surface waters (Seufln, 1973; Goodnight, 1973). In disrupted or polluted habitats, tha severity and general type of stress involved usually can be dataminad by analyzing the structure and composition of tha indig enous aaerolsvertabrata eoaeunity. This approach is being used to aaaaaa anbiant water quality la New Torfc Sues rivers and canals (Simpson 1380a, 1980b, 1980c, 1980d). Mecrolavertebraces also hava the potential for being an important component of toxic substanea woaltoring programs. Host organisms art relatively Immobile and hava life cycles of ena year or lass. Consequently, any contamination found in flald-collactsd organisms will hava been accumoisted dose to tha collection site and over a relatively short period of time. Flald-eollactad macroizrrartabratas already have baaa used for mon itoring tha levels of PCis in various emcarwayi including the Upper Mississippi liver (Mauck and Olsen, 1977); Sarican Say--(Stainken and Bollwegen, 1979); and tha Upper Hudson liver (Slapeon, 1982). Since aacrolnvartsbratas comprise a major ecological unit, results from this monitoring can be used to modal PCS biological transport narhantims In tha Badson liver. In addition, they ara potentially useful for fisheries resource asaagemant. According to Veith (In a personal comicad on cited la Ifclcola Pimia, Inc., 1980) PCS uptake la gain fish occurs primarily by tha fond pathway whan smear column PCI levels ara raladvaly low (i.a. laas than 0.1 ug/l]and principally via tha gill pachsmy when water coueanerations ara highan. MacrolsvsreaBraeaa ara aa important dietary component for aany * game fish, end consequently may ha aa laportant continuing source of fish . contamination when concentrations of PCSa is tha water column ara low. Analysis of macrolnvertabrata tissues also offers advantages over smear semples. Thesa organism* rapidly bloconcantrats PCS* to levels aany thousands of times greater than levels la eha surrounding water. Because tha concentra tions era hlghar, tha organisms can be more accuritely analyzed than mater samples. Crab water samples, unless takaa frequently, may misa pulses La contaminant concentrations. Data for meeroiavertabrate tissues integrate temporal floecaadons for tha exposure period. Also, biological uptake of toxic* is a variable and dynamic process which is dacaralned aoe only by cha properties of tha compound itself but also by such factors as temperature, pH, and hardness of cha ambient water (e.g. Brsglnakl end Shaharban, 1978; Cairns ae, al., 1975; Kssstskl and Bittner, 1973). Similar concentration* of Che seala"toxic compound may display quite different, uptake rate* end bioconcentraeion factors la different bodies of water. One way of determining biological activity of toxics in e specific locadon is to collect end analyze macroinvertebrate tissues. V-2 HONS 009620 Tibia V-l Avarafa PCI cancaatratloaa (a watar, aultlflata caalduaa, and caddlafly larvaa, 1977-1980. (MM * dry al|kt baala; Ul UpId baalai) (Data conpllad froa USGa Hatar Quality Racorda, 1977-1980 and llayaoa, 1982). STATION res CONCENTRATION 1 2 6 7 a 9 10 11 13 14 . 15 X Hatar JL ua/1 39 ND ioa 0.2 71 0.5 127 0.5 155 0.3 10 ND i9 0.2 16 0.2 16 0.1 16 0.2 10 0.2 0.2 Hultlylata TMlduaa (ur/r) JL GUI JA. 15 21 IS 12 , 13 ' 14 11 12 10 9 10 i 0.5 a.7 9.1 7.0 4.2 2.2 3.6 2.2 1.4 2.1 1.4 i . 3.9 37 301 615 433 839 286 388 176 170 198 158 334 CaddlaCly larvaa (ur/r) JL m JL 14 5.2 27 25 34.9 208 26 43.4 254 22 36.1 218 10 27.8 114 29.5 164 IOCONCEMTIATION FACTOR (X I03) Hiltlplata raalduaa OWE _HL * 43.5 18.2 14.0 14.0 * 18.0 11.0 14.0 10.5 8.0 * 1905 1230 866 2797 * 1940 880 1700 990 790 16.8 1455 CaddTifTy larvaa DUB 18 * 174.5 86.8 72.2 92.7 * 1040 512 436 380 106.5 592 * * blocoaceatratlon factora cannot ba calculatad bacauaa FCRa wara not datactabla In uatar aanplaa. MONS 00962 Short-cara Monitoring Prior to dredging, flld studies will be conducted to determine the uptake rata and bioconcentracloo factor for midge larva* azposad In the Upper Hudson SLivar. Tha primary objactivaa of these scudlaa will ba to dacarmlaa 1) tha time ra^uirad for tha body burden of PC3a to ranch ' equilibrium aad 2) tha variability of cha sampling method. During drudging, biweekly samplss will ba eakan ae thraa sleaa: 1) abora tha dradga slta, 2) within cha plume balov cha dradga alts, aad 3) at Scbuylarvllla. Tha first two locations will reveal any lncraasad PCI loadings caused by tha drudging. Tha final alca Is locatad balov all tha araaa to ba dradgad aad will monitor tha lavals of PCIa bain* exaas- portad downs cram. Sltaa 1 aad 2 will ba locatad above aad balow tha dradga slta. Tha complata portability of tha sampling apparatus will allow tha sampling sltas to ba adjusted whaaawar tha drudging slta la moved. Tha aspoaura altaa will ba locatad In araaa with similar currant spaads to asaura that tha control and taat organisms ara exposed to . approximately tha saaa volma of vatar during aach tast parlod. Lont-tara Monitoring Maitiplata aamplars will ba tnarallad during cha first vaak la June aach yaar at 16 sltaa, intending from bdson Tails to Hyaek (Tlgura 7-1) he flwa weak intervals, la July aad ingust, tha samplss will ba harvested aad raplacad with fresh, uaagpuaad aamplars. Ifear another flvs-waak period In lata Sapcambar, cha final sat of samplss will ba collected. Cnddi fly larvae will ba eollactad from five. locndona in tha Upper Badson liver, extending from Thadscn Tails to Uacerford (Tlgura 7-2) . Sampling will ba performed eonenrzanely with tha first day of mnltlplaca aetlvltlas baginning with tha first weak in Jana aad than ae five-weak Intervals la July, ingust, aad Sapcambar. 7-6 MOHS 009622 riRora 7-1 Mulclplaca laapling sites. 7-7 HONS 009623 *> t> flsur* V 2. MulcipUca and caddisfly celltecloa steal - Upper Hudaoo Rlvar. V-3 HONS ' 009624 METHODOLOGY Ylald rad Sampling Procedures Shorc-tsrm Monitoring. The laboratory colon? of midge larvae will ba maintained following machod* la liever (193) and Townaand r_ al. (1981). to minlaize possible eoneamiamclon of tha laboratory acock, all egulpSMnt (aguarla, aaracion devices, ate.) will be non-plastic and solvent-rinsed bafora oaa; tha water aaad will ba carbon-filtarad (available iroa tha Madia Dais, Caatas for Laboratories and laaeareh). bposure packeta will ba constructed from nylon Micas bolting cloth (J60 micron mash openings) aa shown In rigors U-3. Prior to each exposure, nature midge larwae will ba rerred from tha laboratory stock and divided Into groups of approximately 200 mg woe weight (10-13 Individuals). Tha number of Individuals la each group and their combined weight will be recorded. One group will ba retained for control purposes. It will ba freeae-dried end later analyzed along with tha axpoaad organisms eo assure the purler of tha laboratory stock, laeh at the remaining groups will ba placed in an exposure packet for east purposes. the packets will ba axpomad at s depth of oaa mater basaath tha surfaea and will althax ba houaad la a stainless steal wire basket or suspended Individually from small floata. Three-holed coacmta block* will serve as amchors- after exposure, organisms will be removed from tha packets, emumtad, tha madsar of dead larvae noted, placed on lea la salvaac-tiasad glss--era sad returned to the laboratory. VIthis 21 hours they will ba blotted dry, weighed, fyaaim dried sad rmamlghail, than submitted for amalyala. Bead exposure packaca will ba discarded. The expoama period to ba uoad during actual monitoring will ba .dmcasmdamd prior to ebm commancment of drudging, last organisms will be plaead la tbm peel above tha Tbomgiaric Mod Dam aad ratxleved aftar periods of 1, 2, 4, 8, It, 24, 36, aad 48 hours, the mmlytlcal results will.be plotted against time, resulting la aa uptake rata curve. Based on tha literature (see 'Background Section), it la axpactad chat equilibrium will ba reached darlag this two day Cast. If equilibrium ts not reached, additional expertmanta will ba performed with longer cummins Mama Ce.g. one, tan, three, four, aad swan days) until equilibrium is rasehad. The exposure period to be used will be the ioaeat whole day lumbar needed for body burdens of PC3s to stabilise in tha aldga larvae. Ones the exposure period Is datatmlaad, 10 cages will be exposed for eba predetermined das aad the results used to determine the consistency of this sampling method. ___ The above easts will be performed during periods of uniform flow la ehe Bndson ilver when PCS concentrations la ehe water colusa will be relatively constant. Water samples for PO analysis will ba collected at tha beslanlng and at tha end of each test tad at whole day Intervals for tests longer chan 21 hours. Tha average PCS concentration In the water samples will ba used to calculate bioconcencration fsetora for che midge larvae. Monitoring will ba performed biweekly during dredging activities. Thrsa axpotura packets will ba used at taeh of tha ehrte sampling sitas cc allow HONS 009625 V-5 aethods art given abovt. Long-tars Monitoring. Mulclplaca samplers will consist of 10 plates of pressed hardboard, 15.2 es (6 inches)'square and 0-3 ca (1/8 Inch) chick, aounced on as alusinus turnbuekle and saparaetd by small hardboard spacers (Slapson, 1982). Semples will ba eolltccad ac Id aicas (Tlgura v-l) la July, August, asd September afcar exposure parlods of five waaka aach. Exposed sasplert will ba placad Is galvanized ataal buckaci with 3-10 ea of rlvar. waear, disassembled add elaanad with a wida--blada spatula. Tha entire cestasca of tha bucket will ba placad Is a glass Jar, saalad, placad on lea asd racursad to tha laboratory. Within 24 hours, watar will ba removed from tha sasplaa by fllearlng under suction on No. 11 Whatman filter paper. The filtered sasplaa will ba weighed, freaze-driad, reveighed, and submitcad for analysis. Caddiafly lama CTrlchoptara: aydropsyehldaa) will ba collected with a D-frasa aquatic dip net or by picking organisms directly off rocks removed fros tha rlvar. Specimens will ba placed an lea In solvant-rinsad glassware and reeurnad to eha laboratory. Within 2* hours, tha specimens will ba sorted according to tiza and identified to species (whanaver passible) using Wiggins (1977) and Scbuitar and Etnier 0978). Cosspedfic specimens of slailsr size will ba placed together for eheaical analysis. Tha specimens will be blotted dry, weighed collectively, freeze-dried, revelghad, and subsitted for analysis. ''-10 HONS 009626 71r V- 3. ShoTt-toxm uproar* packac, containing aaturt lima of Chironon tlMMi Fabrleliu (Dlpe*ra:ChiroeoBld). v- u HONS 009627 Esch sample la to ba extracted overnight (IS hr) vith hoant os a Soxhlet apparatus, than evaporated to dryness on a rotary avsporaeor (T-4JC). The mix* saxple (or 300 >t aliquot of Ux|r samples) is chromatographed on an actlTscad Plorisil eoluan and alutad with 8 parcane ethyl achar la patrolan* achar. Tha alnaca la eoneantratad to drynasa on a rotary evaporator and dilated with hexane. Tha resultant extract is analy*ad on a Traeor 222 gas ehronatograph equipped with a ,JHi electroa-captaxe detector opazatad In tha DC node. Tha detector tMperacure is 30CC and tha Inlet is 2Z5C. The eoluan 1s oparacad lsatharaally at 183*0 with a (low-rate of 60 al/aln of high-purity dry nitrogen. Tha eoluan consists of a two-netar glass eube (2am IS) pecked vith 10 pareant SE-30 on fias-Chroe Q 80/100 nesh. The detector output Is analytad by a Columbia Scientific Supergrator 3 programmable Integrator. PCI coneantrations are calculated by comparison with external standards using tha |anoral aquation aba a " nanograaa of standard represented by the standard paak b " height (or area) of aampla peak e halght (os araa). of staidard paak d walghe (ag) of original sample a dilution factor, derived aa followa: _ ml of extractIns advent I volume of final extract (ml) ' aliqnot of original extract (xl) Z nl injected Percent liquids are calculated aa follows: walaht of aamola after Soxhlet extraction and fotarv evaporation , dry weight of aample 1 100 taauonalblo Parties Principal lavastlsator - Dr. Karl V. Slapaen, Kaaaarch Scientist m, 20 percant of elma Supervise and counaal Assistant to Principal Investigator during all aspects of program except aample analysis Bandit administrative eattars for the program . analytical Supervisor - Mr. Sam Jackllng, Associate Analytical Chemist, 20 pareant ef time Supervise ehemleal analysis ef samples Including axtraetlon, clean up. Injection, calculation of results and perfomanee of quality assurance activities Assure timely submission of rosulcs to Principal Investigator . and Research Unit of the Department of Environmental Censarvatler. V-L2 MOMS 009623 AttUtaat CO ?rladpI lavsaclgacor - to ba appointed, Assistant hiurdi Scianclse, 100 percanc of Cima * Perform pradredge and roneiae monicoring activities for shett-eaxm monitoring aa daacribad above, supervise and participate In lab oratory and {laid aerie * isalst with {laid work, for long-cam nonicoring * Parfora chemical analyses on samples including extraction, clean-up, injaction, and calculation of raaules * Intarprac raaules and prapara raports Laboratory Tachnlcian (seasonal) - to ba appointed, 100 parcaac of else * isalst with field and laboratory aceivltiaj aa dlraccad by Principal Investigator and iaalseane to Principal Isvaaclgaeor Financial Conaldaraeiona ' la support of this work, $77,077 Is required. This will provide 18 monthsof-earviee by an Isaisrant Saaasreh Scientist (Seats Srada 14), sight montbs-ofaaxrlca by a laboratory Technician (State Grade 9), travel expanses, supplies, and evarhead to ba paid te Health Research, Sac. These resources will ba used to complete all aspects of the short-tarn monitoring and will help with the collection sad analysis of saaplaa for che long-term monitoring. The salary of eha Principal Investigator will bar paid by funds from section 106 of eha Pure Hatars ice, adainlsrerad Jointly by eha Haw fork Seats Deparcaants of toviromsnral Conservation and Baaleh. The Department of Esrrlroamaneal Coaaarvaeloa's Conservation fund will provide eha monies for eha salary of eha Analytical Supervisor aad eha nacaaaary analytical equipment. , 0aalltv iaanrsnea/Quality Control - ill materials usad la eha field and laboracory for holding aad processing samples will ba non-plastic tad solvent-rinsed before oaa. is part of each share-ear* east, a sample of laboratory scock mldga larvae will be aaalytad eo assure purity. Sample tracking records, such as ehoaa shown in eha Quality iaemrsnea Pita, will ba kept for all samplaa. The analytical laboratory will perfotm tha following Internal quality control it eha beginning of eha project, eha initial Somhlac extraction will ba rapeaead to determine eha pareane recovery of eha flrse overnight extraction . Laboratory-generated replicates win ba analyzed at eha rata of one pas 20 samplaa HONS 009629 7-13  Slinks (Including reagent checks) will b analyzed at a raca of ona par 20 ssaplas Spiked blanks and spiked sasplas will ba analyzed ae a raca of ona par 30 isspla* Othar procadaras such as preventive aalncananca and calibration of balances and recorders sra given in Section 3 of cha quality Assurance Plan ' for this project. SAZA ABALISZS Short-tarn Monitoring The triplicate saaples used for each exposure will allov cha application of Analysis of Variance (AITOVA) and Least Significant Difference (LSD) casts to assess cha significants of any differences In naan PCS concentrations between stations and between different exposure periods st the lane station. Lon-tra Monitoring ASOVA and LSD esses can also be applied eo the nuleiplata and caddlsfly larvae data sets to detect significant yearly differences in PCS concentrations throughout the river. These taata hare already bean need to show significant differences for auldplata and caddlsfly staples for the period 1977-1900 (Slapeon, 1962). inwinc seaidols Short-tern Monitoring . Staples will ba analysed monthly dnxiag dredging, Midge larvae fro* two consecutive biweekly exposurea will ba analysad concurrently to aeke efficient bee of personnel dan and laborntory equipment. Sample extraction and dean-up will cowence within ona weak from the time the second saapla sat Is collected. Saw data And intsrpratad data will ba cranaaitted eo the Research Unit of ehe Deperaane of Environmental Consarvadon within fonr and six weeks frow the date of tha second eollacdon, raapacdvaly. Lonn-tarm Monitoring Analysis of aoldplaea samples and caddlsfly larvae froa each year will ba completed by April U of eha following year and the results transmitted to tha Principal Inveedgacor. A final report including interpreted resales will be prepared by June 1 of tha same year. V-1A MOMS 009630 irrranra exits liavar, R.D, 1963. A rearing tachniqua far eh* colonisation of chircnonid idgas. Ana. Zaeoaol. Soc. Am. St (2): 133-136. Braginaki, J.U. and E-7. Sheherbaa. 1979. Acuta eoxieiey of heavy aetals to aquatic invert abratas under diiiartat taaparatura conditions. Hydrobiol. 14(6):86-92. Cairns, J. Jt., A.6. Raath and 9.C. Farkar. 1973. Effaces of eanperaeura on aquaeio organism sanaieiviey eo aaltetad ehaaicals. Hydrobiol. 47(1):133-171. . Cnthnan, EJi. aad H.I. HeKaiaoy. 1991. A Chirononus cast ana bioaaaay for taating ayuthaeie foal produces and affluents with data on acridine and quinoliaa. Boll. Environ. Centra, Toxicol. 26<3):601-903. Derr, S.X. and U.J. Zabik. 197A. Bioaceive eoapounda la eha aquatic anvirooaanc: atudiaa on eha node of opeaka of OSS by-eha aquatic *Ldga aironcam taneaaa (Dipearn:Chironoaidaa). Arch. Environ. Cootaa. Toxicol. 2(2):132-16A. . M|i, Z.X. end T.X.. Thais. 1979. Efface of char teal spcclcelon on ehc "f***1* of copper by ChlrooaMS eantsns. Environ. Sci. Tech. 1(10): 1287-1289. Caafia, AJL 1971. Sac of naczoisvarcibrataa in eha assasaaane of usear quality, pp. 96-116 Cairns, J. Jr. and E.L. Dickson, ads. Biological achads for ehn asses want of untar quality. Am. Soc. Tasc. hat., Spa*. Tubl. Ho. 329. geedaighe, CJ. 1973. Zh* ooa of lcroiavartabrates as indicators of ttnan pollneion. Trans. Am. Mcrasc. Soc. 92:1-13. .Johnson, U., t.C. Sonadcrs, H.O. Scndars and I.S. Canpball. 1971. Blolog-. leal magnification and degradation of DDX aad aldxla by fraahuneax inwartabratas. J. fish. Bos. Board Can. 29:703-709. Julia, l.M. aad H.O.'Saadazs. 1977. Toxicity aad accuamlaeion of eha innscelcide Ttdaa la freebuncar lavareabrmtas aad fisbas. Trans, la. fish. Soc. 106(A):396-392. Kswacski, J.A. and M_A. Bietnar. 1973. Opeaka* alimiaation, aad bioexaasfoncelon of eha lsnprieida 3-erifluofeaaehyl-4-aicrophanol (TTH) by larvae of eha aquaeic nidga Chironoous tantana. Toxicol. 4:183-194. Laversaa, C.J., J.P. Cissy, 7.7. Uadrua, S. Ccrould, J.V. Bowling, T.E. Fannin, J.D. Haddock aad S.H. Barta11. 1982. Xinacies and bioeraasferaation of ban*o(a)pyrana in Chlronoous rioarlus. Arch. Environ. CooCan. Toxicol. 11:23-31. Macak, K., R. Buxton, 9. Derr, J. Dean aad S. Sautar. 1976a. of liadaos eo salaccad aquatic invcrccbratcs and fishas. E7A-600/3-76-046, 38 pp. Chronle toxicity Ecol. Rat. Sar. 7- 15 MOMS 009631 Macak, K. Buxton, S. 5wt, S. Sailiu tad J. Dttn. 1976b. Chronic toxieiey of acraxine Co aelaetad aquatic invertebrates and fiabaj. Ecol. Has. Ser. EPA-600/3-76-047, 58 pp. Malcolm Ural a, lac. 1980. PCS hoe apse dridgla( program - cpper Hudson River, Nam York. Draft Environ. Impact Stacimanc, N.7.S. Dope. Enviroa. , Cons. . Mauck, W.L. and l.E. Olsoa. 1977; Polychlorinated biphenyls In adule mayfllaa (Baxnnsnia bUlaaata) from tha Uppar Mississippi River. Sail. Enviroa. Concern. Ioxleol. 17 (4):387-390. Mayor, r.I., P.M. Mahrla and H.O. Saadara. 1977. Residua dynamics and biological affects of polychlorinated biphanyla in aquatic organisms. Arab. Environ. Coneaa. Toxicol. :501-J11. Nebakac, 4.7. and T4. Pogliai. 1974. Efface of polycblorinaead biphanyl'a (PCS'a) on aurvival and raprodocelon of Daohnia. Caomaraa. and Taovcaraaa. trana. la. Tiah. 5oc. 103(4):722-728. ---------------- Paltiar, H. 1978. Maehada for measuring tha aenta toxicity of effluents eo aquatic organisms. Ecol. Baa. Sas. EPA-600/4-78-012. Sadler, H.O. 1935. Biology of tha nidge Chlrooogm eanCana Pabrieloa, and nathoda for ita propagation. Cornell. Ooiv. 4gr. Exp. Sea. Man. 173:1-25. Saadara, 1.0. 1977. toxicity of the anllaacicida Bayer 73 and raaldna dynaaica of Bayer 2353 in aquatic invartabrataa. O.S. Fish Hildl. Serv. Invaat. Plah Cent. 78:1-7. . ' Saadara, H.O. sad J.B. Chaodlar. 1972. Bicloglcal aagnlftcation of a polycblorinaead biphenyl (Aroclor 1254) from nacar by aquatic iavoreabxacaa. Ball. Environ. Ccaeam. Toxical. 7.0) :257-263. ScbaJCar, 6.4. and 94. Itniar. 1978. 4 oannal for eha identification of eba larvae of eba eaddisfly ganarm Hvdroosvcha Pictae aad Syhitnnavcha Olmr la taatern and General Barth tmerica CIrichoptara:Bydropaychldaq). . Enviroa. Monit. Sar. EP4-800/4-78-060, 128 pp. Siapaon, X.H. 1980a. Maaroisvartabraea anrvay of eba Buffalo liver Syicaai, Baa York 1976. B.Y.S. Dope. Health, Environ. Health Bap. Bo. B, 51 pp. Slagoon, X.W. 1980b. Macrolnvartebrata survey of the Alleghany liver, Bew York - 1975. B.Y.S. Dope. Health, Environ. Haalth Rap. Ho. 9, 39 pp. Siapaon, R.W. 1980c. Macrolnvertebrata survey of tha Mehauk Bivar-Barge Canal Syataa, 1972. B.Y.S. Dape. Health, Environ. Haalth Bap. Ho. 10, 43 pp. .. Simpson, K.H. 1980d. Macrolovaresbtata aurvay of eha Niagara Rlvtr - 1976. K.Y.S. Dape. Health, Environ. Haalth Bap. No. 11, 29 pp. Slap tar., K.W. 1982. PCBS in nulelplata residues and eaddisfly larvae from tha Hudson Rivet, 1977-1980. N.Y.S. Dape. Environ. Cons. Xaeh. Paper, lr. prep. 7-16 MQNS 009632 SBCnCH VI, SEDIMENT MOJITORING PB0GSM1 PCS Ctait and Bnraai.i of Mtar Tlaiaarrh Mw York Stata Dapartnant of Bavlromatal Ccnaarvaticn MOWS 009633 anaceucncM For a 23 year period ending in 1977, an sseimatsd 350,000 kg af polychlorinated biphenyls (FCBs) discharged to th# Ftadson River, . acewuletad in riwr sediments. pea transport downstramn by smnl mechanism has resulted in orntamlnation of river sediments throughout tha 300 Iqb reach of river and estuary of tba Hudson River. Anthropogenic activities including dredging and removal of a dam at Fore Edward, have also mediated transport of PCS* downatramn. Vfcila tba apart a,1 distribution of sediment PCS cancan i* highly variabla, there is a marked gradient in sediment PC3 downstream. Bopp (1979) baa estlmatad that more than 157,000 kg of FC3 raaida in tba aadlmanta of tba Upper Hudson extending 80 km southward teas Fart Edward to tba Fadaral Don at TToy. Approximately 76,000 kg are in tba aadlmanta of tba 240 km tidal rivar and estuary below tba They rw, Rivarwida PCB corrtaninaticn has resulted in partial castristion of oesmagcial fishing and seexesticnal fishing in tha Oppar ifr^erey (aaa 'page IV-3). Several measures, including the eliadnatlcn of the PCS discharge and stabilization of nearshore aadisant deposits exposed following ranoval of the Fort Edward Dan, vara isplamantad to aoealarata tba xatum of fish PCB concentrations to acceptable Levels. liar poeamCially prolonged onntsmination of the Hudson Rivar fishery and tba peasant opportunity to reclaim, at a reasonable asst, a large PCS mas In tba scat t.mi.jHilnatad reach support tba proposed |^Mflfw|'i***** of teadglag and a:mpa1artm of asntaninatad sediments from tbe Island Pool. Earliar investigations of varilmnt PCB distribution in tba {reposed dredging area Indicated twenty diaezeet *bot spot* areas having an average PCS occearrtraticn in aveaae of SO ga frofflirira and Quim, 1979). Mats than 300 sediment sacplee, including appeoadmaoaly 100 'ooraa oollaetad tea tba Thnipman Island Raol for FCT and rawfiue analyaas, in additicn to bathymetric infouiaLien, cuunUtad a delineation of hot spot arasa (sea TOfflandra and QuIjb, 1979). The results indicated eonaidarable vratlel variability in PCB distribution in tba Theapacn Island Pool. Ha results of these investigations also indicate that tba satadal oeeqaies a relatively shallow stream within tba aaillmmiL bad. Tba ocapnalticn of aadisants, i.a. particle size and ergmie content, accounted for much of tba variability in tha distribution of PCBa in tbe project area. Tba heterogeneous distribution of PC3* in tba project area poses soma problems for efficient ranoval by dredging. Tbe removal efficiency mist be controllad, not singly nonitorad, during tba operation. Finally, tha PCB distribution in tba river's post-dredging repose mist be doctxentad to permit uaaiSTt of river response and subsequent evaluation of tha overall effectiveness of tbe demaistration project. Tbe sediment monitoring program has tbe following objectives: irprera tbe definition of areas to be dredged ir.cluci.-g prioritisation based user, credibility; VT .1 MONS 009W34  inprove dredging efficiency during the project; docoasht the post-dredging repose of PCB-contaniinatsd ssdisents in the Upper audscn for the purpose of assessing the river's response to dredging and net. effectiveness of tbs dsBonstratioi project; and define the ness of Ps encapsulated in Sits 10. 71-2 HONS 009635 mcnztoricc stsauey Asms to be dredged in tba Thcnpacn Island Fool will be defined baaad upon sediment SCB data and potential erodibility. A bathymetric survey of the Thengaon Island Fool will ba performed using a 25-foot sounding grid and hawing borlzcntal and vertical accuracy specifications of i S ft.. t 0.5 ft. H* survey data, in addition to sedating sadimant PCS and sadisant cagosition data sets, will ba usad to dixact tba pra ilra.lije sailing of river sediments. Additional aadisant PCS and cgigcslticn analysaa will ba usad to dalinaata, vartieally and hciircntally, araas containing gran-tar than 50 pen PCB*. 2* djatributien of haavy natals, in particular lead, will ba asaaaaad using vartieally integrated sediment sacplaa. Tba relationship bacean u rZa and PCB concentrations will ba advanced for latar uaa as s surrogate analysis for deciaienSjOaysming dredging efficiency. During dredging. Lathymetric, PCS, and iJ/Cs maasursnents will be used to assess the effactivensss of dredging and to fonnulata recamandaticns for iagaovanit of tbe dredging methods. ' During tba lata spring and sonar following dredging, the iheagiaui amA peel, in addition to other araas in tba Oppsr Hudson, will bs rasnqplad to define tbe pcst-drsdging repose of POB-ccntaminatad .. in diadgad and redradgad areas. Ibis Information in **M**rw< to data collected by tba water mitering progran and an investigaticn of ifr PCB istaractiens (see Appendix B), will ba usad to assess tba affactivanaaa of tin dmrnstratien project. Following sene sfahlliraticn of tba sadimwnts in tbe aentsirsant site, tba aacspaolatad sediments will bs smglsd to datsmins tba aass of KBs contained by tba site. HONS 009636 MEQEEQLOS? field and Smllnc Procedures . Om bathymetric survey at tbe T?myean Pool will be conducted by Raytheon Oeaan Systems Ccapazy (ROSC), East Provisoes, Reds Island. Copiss at tbs raqosst for proposals and tbs HOSC proposal nd contract ara on fils at HTBllH*. Tba following excerpt from the HOSC proposal provides an overview of tba ROSC approach: ICBC propoasd to util Its tbs "Mobile Mapper* data acquisition systam, .a Motorola Mini-Hangar m . electronic navigation systan, and tba Baytbson DE-719B Fktbcnstar to aoqoirs bathymetric data in tbs survey arts, The "Mfoile ibpper* systan was developed by BOR to provide a flexible data aoqaisiticn systm for hydrographic surveys. Iba systm, basad an a liawlsLB Fartfirfl 9823 aayutsr/ialailator, prcwidss survey pm- and post-plots, raal tins trade plots, hslMssi Information, and mgnstir data raoording. Iba survey vassal, a 22-foot Aquaapart with a cabin t0 bOQM tfao *1-- wmrrif will ba outfitted with a oniqaa strut aaaanhly, ptuMtrtlnq optimal h>^ for tba tzansdocar and asvigsticn systan raapendar to foeilitata shallow water data artjrlrltlan. Ibs transducer itself will ba iwwrtad at tbs top at a wstar ftHad cylindar with aa acoustically tsanspszait dlaphta^ at tba botbeau Hals cenfiguraticn coipsnsatas for a water srimding limit at appzenimataly 1.3 foot, basad on tba EC Tin tzansdocar 'ring down* characteristics. All survey linas and raarmder aoerdinatas will ba . plotted qb "boat abasts* pzlcr to tba start of sorvwy cpsrmtions. Ibis prooadurs will optimize survey time sod preclude data gaps by providing a precise, affidast sgsnm of survey events. All data products will ba prodocad at foytbaen's noiyutar facilities, utilizing stats-of-tbs-art hankers and softmara. Tba data products at BOR will includai 1) contouring plots of gylar basing a seals of 1 in. - 50 ft. with a 250' grid of Haw Hock Stats Plana Gocrdinats systmi 2) approximately 1075 lataral cross on sylar at tba 23 ft. intarvals; 3) annotstsd data printouts nd walog depth aomdinga; and 4) a data tapa containing plana oocrdinatas and aoendinga, scccapanisd by writtSn doasaotation. Ssdimarrt cam will ba oollactad from tba `xspson Island fool daring saamsr and autuan, 1982, by IHSOK personal using a 24' pontoon . bone and pnaueatic coring equipment. Stapling locations will bs gmsrally locatsd baled upon tbs existing data set and tbs bathymetric survey. A range-Sziauth digital positioning systnn will be used to 71-4 HONS 0 0 9 6 3 ? precisely define sanpling locations in tha field. In tha field, visual inspection of material in benthic grabs and bathymetric features of the area measured by a fathometer will guide positioning of coses. The sole of bathymetric features such as sandwaves, in contributing variability to the spatial distribution of FCBs, will be given special ccnsideraticn. Assessment of svpiing errors will be tt* goal of several discreet studies. Cores will be extruded, sectioned in the field, and placed in appropciatslylabellsd containers required for the individual analysas ' to ba parfoarad. Coras will ba sartirred arbitrarily in Hu of visible strata. An average of four sections par cere are anticipated. Graduate students frcm Rensselaer Polytechnic. Institute, under the direction of Or. Thomas Zinnia, will measure sediment shear strmqth using vane shaar equipment during .the pre-dredge -emipling survey. Data to be recorded in the field will include location an tha Hew York state coordinate system, depth of water adjusted to tha spillway elevation of the TVmpara Island Oms, core section intervale, core length, and vane shear strength, In addition, coca aespacticn and qualitative cements regarding sanple type will be logged. The past-dredging sampling will use the same sanpling methods but will not be limited to the Thrnpann Island Pool. Horizontal control for both pre- end poet-dredging surveys will use the extensive haeeUns traverse established by Homan Porter Associates in 1980. Initially, during dredging, the effectiveness of ecrtanirated sediment emoral will be made using an analog fathometer. Grab sediment smaples, collected by a ftnar or Shipak grab, in addition to core sniplee will be tafcan with nenaideration to the altered, and probably irregular, bathymetric faaeurae of tha dretjsd areas. Conpositing of grab saplea will ba used to iwermaua problems of spetial heterogeneity in dredged arses. The digital range sTjjmfh positioning systnn will ba used far locating amp!as and bathymatslc transacts. Following some stabilization of dredged material at the ccntaianene site, the site will be wepled to determine tin mass of FOe being isolated. Soil oaring equipment will be used, in conjunction with an lncemlve sanpling and vertical and horizontal ooipoaiting schene, to the total mass of PCBa in the site by analyids of a limited Sample Analyses Sadiarnit samples collected during summer 1982 far the refinmmnt of hot spot locations will be analyzed for FCBs by Syracuse Research Corporation (SRC) and to the PCT Project laboratory. tha availability of analytical liaourtaa in an existing oentract bee men SRC and HtSBBC, delays in the development of tha project's laboratory, and tha-naad to develop dredging specifications in tha ismadiate future supported the declaim to initially use a ccntsaetad laboratory. Apptoxjmataly 200 sadimaRC staples will ba performed by SRC. Subsequent analysas will be analyzed by the project's laboratory. Both ' laboratories will routinely use pocked column gas chromatography. VT-f HONS 009638 Samples will be stored firotan until analysis by the project laboratory. Rivar sediments and interstitial sediment water will be analysed for haavy metal* by atonic absorption BfTtrnphnnmen-y at tha Bwiroreantal Health Institute of the Haw York Stata Department of Health. Sedinant tcaceura analyses will be performed by tha Project Laboratory. Particle size analysis will be performed an a limited ruber of sediment samples vising a pipette method at the Soils qjqssetarlzaticn laboratory. Department of Agrcnany, Cornell Ohitarsity. a7Cs analysis will be performed on selected sediment uncles collected by the predredging ^survey in additi^to sediment samples' collected foxing dredging, lbs contract for Cs analysis will bs either negotiated with tha New fork Stata Oeparttent of Health or bid through an HFP process. .. HONS 009639 Beepcnsibla Parties Messrs. Jeffrey Schmitt and Michael Willis, NXSDEC, will be responsible for the overall sediment monitoring program. The pre-dredge bathymetric survey contract being omduct-Hd by Raytheon is supervised by Michael Willis. Dr. Sujit Banarjee, Syracuse Research Corporation, and Join tyan, WYSDEC, will be responsible for sediment PCB analyses. Dr. Liquet Hussain, NXSDCT, will be responsible for heavy matals analyses. Dr. Kenneth dsn, Cooiell Ctaiversity, will be responsible for particle sire analysis. Dr. Thomas Zizmda will be responsible for definition of hot spot erodibility. Ota analysis Pie lireilija sediment PQ3 data will be managed and analyzed using a Qhivae 1100 aonputar. The distribution of sediment PCB in tbs Thcapsen Island Pool will be mapped by a digital mapping system to delineate dredging areas using PCB texture and bathysattric data. The distribution of heavy metals in dredged areas in both sediments and intanstitial water will be analyzed using a hydraulic dredging model developed by Adana and Datby (1980) to project heavy iret-sl concentrations in tbe ..... . site afflimt. During dredging, sediment PCB and ^Ca concansations in of dredged areas and bathymatric maasuremants will be used to aaaasa hot spot rmnoval efficiency. Such analyses will be ait tel within a few days of sample and data collection to permit rartredging if nacaeaery. The post-drafting survey Information will be splayed with the ~l'* of sediment water Interactions developed by a contracted research Investigation Uppandir A) and the data fron tbe long-tens water monitoring program, to utaaa river recovery and respanat to dredging. a HQNS 009640 HEmetas Adana, D.O. and D.A. Daitoy. 1980. A dilution-nixing modal designed for dredged eadimants in frasiMatar systems. In: R.A. Baker (d.), Contaminants and Sariimanta, pp. 373-392. Ann Arbor Scianea Publishers, Ann Arbor, ME. Bcpp, R- 1979. The gaochnnistry of polychlorinated biphenyls in the Budaen River. ffcD t-heeis CaluBbia University, 191 pp. Tofflidra, T.J. and S.O. Quinn. 1979. ia in the 0pper Hudson River: napping and sediment relationship#. Technical paper No. 58, Bureau of Water Research, New York State DaparScant of Enviramental Canaarvation, Albany, N.T., 140 pp. MONS 009641 section vn. pbdiecxzcn cf hcman health mo the mnsatem from dispersion cf pcbs RESQXSXK3 FICM THE HUDSON RIVER PCS RECLAMATION DBCNSStKriCV PROJECT A PROTOCOL FOR DECISION MAKING- Buraau of WNtar Raseaxch Division of Vfctar NSS Department of Bivixonnantal Conservation MONS 009642 Protection of Henan Health and the Bivizoment firm Dispersion of ECBe nasulting from the Hudson River PCS Reclamation Damonsfciatlcn Project Protocol for Decision Making Introduction The major abjective of the project is to restrict the long-term environmental dispersion of PCBs currently located in the sediments of the Thoigacn Island Pool for the protection of fasten health and ttvircnnental resources. The activities of the project have the to Increase, for an seanrned short period, the rate of FQ dispersion in the environment. In assessing the Project's technical feasibility and the net faaen health and envlzannaRtal benefits, projections and pest sepscrisncs were wployed. That is, tha likelihood of ateaeding ossrtain PCB concentration limits, which were assigned by environmentally protective mens, was assessed by application of a substantial body of PCB anvircmantal and fasten health research and_ "the 'tjapertsnaxt's aoqparianoa in ncnitoring-dredging procedures in the Hudeon River, cn balance, the likelihood of mraai.Unq those protective limits and the costs of contingency measures to bring concentrations within acceptable levels are outweighed by tha benefits of the project. aswaning that certain PCB anvirciMental concentration limits should not be wceeded, the tasks to be undertaken are the msasuzamant of ervircmmntal ocnoentrations during the project's active phase and the determinerion of whether those levels are acceptable, and, if not, the types and duration of responses to being concentrations to acceptable levels. The strategy and methods of sawssing environmental levels have bean presented in-detail in previous chapters of the monitoring plan. The decisions concerning the acceptability of monitoring remits and appropriate responses are tha smjor topics of this section. Tha mvircnnantal concentration limits controlling the dec!linn making process and their technical bases are sumerirad in Table 1. The Division of Vfcter, NYSDEC, has asmmad the protective posture thet "levels of concern" are levels that should not be Background and Strategy lha formulation and testing of hypotheses is essentially the heart of decision theory. In the statistical tasting of hypotheses, acceptance of the hypothesis as true means that there is insufficient reason to reject it. However, rejection of the hypothesis is the conclusion that it is false. Tb best serve the Interests of the decision makers, hypotheses suet be carefully stated. Generally, that which one hopes to reject should be stated as the hypothesis. vn-i HONS 009643 Tbs interpretation of analytical results will use the null hypothesis: the envircnnantal concentration is at or above the acceptable limit concentration. Based upon sampling and analytical errors, and a limited raster of smplas, there is a definable chance that one would reject this hypothesis whan it is true. An axasple of such a type I error world be an asaeaament that environmental renditions would be acceptable, when, in fact, the true concentration ernaads limits. 1hare is also a chance that cn occasion one would accept the hypothesis while it is false. Bcpcassicn of such a type error would be an assesanent that anvironmantal conditions are unacceptable when, in fact, they are. Tor this hypothesis, the nonsequence of a type I error could be the cmpremising of hrnan health and environmental protection. The consequence of a type II error torld be the needless use of project resources to assure that levels are acceptable. In the field of statistical testing of hypotheses, a is typically defined as the -prBbsbillty..of_a-Jgpe. I snd_&.__ rha_prrhefcriHfy of a type H error______ The values of a and 8 are interrelated such that design to ndn-inriTs type I errors increases the likelihood of type IX errors. U anvtrmnantally conservative focus on restricting the Incidence of type I errors that this ptogran will use, leaves the probability of type H errors undsfinabla vsrlaas specific alternate hypotheses are farmed. K specific hypothesis will be used to assess the probability .of a type IX error. The first part of tbe strategy to be mplcyed in screening results as they cons from tha project laboratory assigns specific ocnowtrmticna for reepmsa band upon a designated probability of type X errors. The assignment of these ocncsntraticns is a function of both tha acceptance of a value of a and the stapling and analytical errors that will be asaumed kncwn and having a normal probability distribution. In this program two values, a. anda2 equal to .05 and .25, respectively, are used to calculate two concentrations, C. and C,, relative to a defined concentration limit, C. . Results gfeatar than C, will elicit the response of iaplamtaticn of contingency assures and accelerated data collection, naaults greeter than C., but lees than C,, will be resprirVari to by increasing ths intensity of data collection. Results lass titan C^, will not require a the general fortmla for calculating Cj and C2 (Cn) is CnZ M"*0! where Z [*,,] is ths ordinate associated with the emulative area, tmdar the standard normal distribution equal to .05|ajor .25 [ajj and 9 is tha theoretical population standard deviation attributable to ssspling and analytical errors. . vn-2 HONS 009644 Par the air concentration limit of 1 ug/m (C.) and a cenbinad air smipling and analysis population standard faviJticn,- <r - . IS ug/n** as proposed by the farojact's CP*-GP plan, and Z-|(*i - .05) 1.645, C, .75 ug/m1. A simmery of results of C. and Ccalculatlons for various limits and tha presently1assumed values for are praaantad in Table 2. Table 2 also presents the probabilities foe a type I error when the actual enviromantal concentration is 2 C, and foe type U error whn the actual environmental concentration iS 0.5 C,. Cna can see that tha probability of not responding to a true environmental concentration of twice tha level not to be exceeded is extremely mall. Hie probability that one would isplatent a contingency measure when the true envireixnantal concentration is half the level which should be run euleil is less ttwc 10 percent for water samples and less than 0.4 percent for air iwplss. Presently, tha values of c are beet estimates and would be updated during the asurse of the project based upon QC data. fabaaqnant to apprcval of tha project an APL interactive program^ __ 'Would Ei'fSKVbpad'for tha''project management to'asseas'type I and ' type H errors far other values of a , v , C^, and C^. A general decision making protocol was davalopad to eliminate the need to address each of many unique possible series of occurrences and decisions fallowing the production of a monitoring result greeter than C.. The protocol is preeentad in algorithmic fashion in Table 3. The genual attributes of the protocol in addition to some possible variations far problems related to specific sources will.be described. The increased intensity of data collection that fallowa tha production of a result greater than C, involves replication of --pH"? and analyses and tasting thehypothesis that the sampling maan, 7 is equal to C, or 10 C, at the .05 level of significance. Tagil Inq seen values equal to, or exceeding, C- will result in the iagil--ntstion of contingency options far ranaqy of the situation or if contingency options have bean exhausted, cessation of the project activity identified as the likely contributor to the unacceptable condition. If smiple mesne mnjaad the arbitrarily defined level of 10 C,, than the probable project activity producing that ocntriburticnHrould be halted. The protocol provides far the graded inpl--ntation and maintananca of contingency options and cessation of project activities in addition to the relaxation of contingency options and- tha reemption of project activities. Data collection will generally be determining the rate of decision neking and 24 hours can be generally assured as the time required to update ample Table 4 provides the array of contingency options to reduce tha potential sources of PCB dispersion and protect human health Airing periods of unacceptable exposure to PCBs. As mi<it be expected by a protocol that attaopts to describe a course of action mrbracing moat possibilities, it is deficient in sane specific areas. By design the protocol is reactive, that is, VII-3 HONS 009645 decision* concerning data collection and contingency measures are in response to existing conditions. In application, sane forecasting, based upon prior research, and esqperlence gained during the course of the project should permit the protocol to be more active. For exaaple, knowledge of the effects of oertain meteorological conditions and PCS losses to the atmosphere, or hydrological conditions and time of travel to the expression of PCS losses from the dredge heed, at the Waterford Water Treatment Plant should permit a prior assessment of conditions and determine the appropriate response. Such projected values would be treated as the seapla mean x in stages 2 and 4 in the decision making protocol. pon project approval, the daoiiim making protocol would be ede available to project management through an interactive APT, program. vn-4 HONS 009646 4 TJbk 1. ftwrtmn--tel KB i fewlraramul to ba W Description m a Rmlt of Kojact KB Uni OtfliMd by UkaUhoad at Ooammtom Bail Cor Mila wlar Wl* *t Ikterfimi II - 4,1,9 BriMto drinking water walla II - 0.0,0 1.0 ug/1 In tsMUl wtar 0.1 ug/1 0 wav rut 703, standard far claaa OBI Hnlaui elevation sxpectad Urincjiaurdato ' dradgiiu fan! ntan flow ia 0.1 ug/1 above atedant n Unli. dndga plan ia not ngajral to attend tafonl l.i In dcwaUMa. Sima IIm taterfoctj lntaln ia U be downetrnagi oC drudging act ivity and a M peroant ICB reaowal efficiency daring wter treeteant haa ban dam- trated if ia tmlihely that tea 1.0 up/1 will faa nimtel KB algn^Un thraugpi clay nateriala ia aamnrffngly alow; aonMninatirai in highly tn^ifcaly. VI feasibility ^-"tt on drudging KB-mntaa Anated aadlnanUi O*Belan * Gera Hrim tlwr water KB Tteatability. Study. Bworaticsl Migration 1 rate# of water and roa through clay nateriala in *Vl faaaibility II " 4.M tecility aflluaat fangs crops III - 1,1 ISO ug/1 1 0.2 ug/g SKBS affluent Uaitetiona hmalawf of this Uait far a 24 hr. period would rntpiire tea handling of a vary larga dint uu oonteinlng aora than 1,000 (pi Ri. hnadni la oonaidgrad unllhaly. VI elutriate teats a . aatiautea baaed igoi 1 partitioning theory. m telacaraa Crop aadaplnatlan Bon tin Uni far faad IM Unit any ooour at air By extrapolation uaing K* date fnaa planta oo sC m # 1 HONS 0 0 9 6 4 8 Air l i ii Harter sit* I - 3,4,*5,7,l (Moading ATM I - 3,4,5,7 IMp I - 3,4,5,7 pmbioing mlaaU , pcs lmla gf M) ogM* and aim*, lOuch level* nay ba antlrlpafad within tOO m of tha nmrMi--il lit* li.a. 0.5 (541 Cll worn tine* to 1.0 (421C1) weighted g/b* **fn* for 10-hr tort- day, 40-hr workweek 0.5 (541 Cl| MOfiM tiam- to 1.0 (431C1I weitfitM q/*1 average for 10-kr worfc- day, 40-hr . worki oak 0.5 (541 Cl) N10M tl to 1.0 (42IC1) weirded q/b* average for 10-hr work day, 40-hr workweek Hipest atnpqharic PC* . level anticipated at lagnnna la three orders of angwltnda lower than MICGU itmkrd. Higher than* calculated level* could occur- at naa-paieecert area fiear Influent pipe and during adverse neteorological oonditicna.j Itotal ataKM^iharlc PCS levala wailtlq free oauUtiva flua of pcap froa exposed artinanta held on barges and alurrlad fay transport, river water, and |he nnntalrawot site itself) depend upon sur face area apd aonoentratlan of PO in eqioaad aodieonte, slurrying pfocadiree, and nateocologlpal aondltlons. Maxitem pnptbla increase over aablaat In total PCD* In river water are 0.1 ug/1 for hydraulic and 0.4 to 0.5 ug/1 for cl--hell dredging. Volatilisation feem river wttr would be niniael at both levels. Greater inut on air PCS levels (a antic ipated wlth*cl--hall than with hydraulic dredging die growing in knowi air acncantratlois in atiiliaa cravtoted by on. MydraOual eatlaetea of axI-- praftuble flux to the aiaoqheie baaed tpn partitioning thaoryy MPQM and ll aodal calcalaticma of critical dteaolvad ICO concentretiona In legoona. PCS air data fraa wramn/ OCU iaeeatlgaticna at dap altaa, dredge qoil and raanant areas, and daeay HydroOial, MtfOM and MPI aatinates of PCB flux rates. W( feasibility studies cn dredging of PO-oontaelnated aadlaanta, using lose rate eatiautae for dredging procadaes during low flcwj MMDflC/ Oil PC* air data. i I - 3,4,s,7, wan 24 - to nlutlni 44 Wntitbl Mr KB lawl llatad in pnadli^ ' BmM tot j .Mi* |a M* tlw kMr than tot Ulan, la tlis ua lately to ku --u-WiI I Table 2. C^, C^, Cj concentrations and apart fig type I and type 13 error Concentrations Error Probabilities <x units 1.0 0.1 100.0 0.2 1.0 1.0 ug/1 (water) ug/1 (water) ug/1 (water) ug/g (plant) ng/m1(air) ug/mf (air) e 0.25 0.025 25.00 0.05 0.15 0.15 =1 .59 .06 59.0 .12 0.75 0.75 =2 .83 .08 83.0 .17 .90 .90 Type I at 2 C. w'hen x <=1 <.0002 <.0002 <.0002 <.0002 <.0002 <.0002 8333 Type II at 0.5 C. wben x - Cj .09 .004 * See table 1. ** See Project QM3C Plan. vn-a HONS 009650 TS9600 SNOW Tabla I 1.1 option ta riict. kutln mllorlfig pnvlMQM^ fit* M at diU lotapatatla tated Matin a . la luxxa. ntlatln arno - o if x < c., go to l if C. < i <C_, go to 2 if Cj x x, go to ] 2.1 t>t aolioction at incraaaad Intanxltv. rxpllratlrxi mffixin MxxytlnM t ---- a---- ------------. I. it it ci l<* Ciro, 9o0cto., 1901 a <, 90 c r j.i l^ilwwution of contiimwicv --i onto - GPENO 1 axwr - 0 I Ifil--it qpUon forao) Go to 4 *1 IMutwnn at contlmnxi i mlataln cycle* [onto] OOUHT m comt I Go to 4 M MmUnofonUramj MUx tytion [BHIB] ' onto - i ic cmo o, 90 to 2 7.1 I BSqfcct ctivity pntori^ PS - 0 if OPDO < )( 90 to 3 if UPDO k 3( 90 to 4 M i wolict activity M- I 90 to 4 4.) pxaoxx.. or naintain incraaaad data oolloctlon intmoity. --Uxta raapcnaa to qptlan flWB 11 project xtxtua la actlva Ira - 1|, or to cmaatltai of nartain projact activitlaa (n - 0|. Amnx > la inknowii paxtan anylx--------_ g. if IX < C| and lour < i|gi to s if W t O and (COUir a II ml if (X < CT) and (auir a 11 andlra-0|, go to go to I n "d WT< II. go to J t <IOCp and KPDO a II, go to 7 lv > to 7 oondiMTM- Table 4. Contingency Options Bwixcnnsntal Catpaisnt - Hater target OPTOO Description Public Hater Supply at Metarfard 1 Reduce cutterhead REM and swing speed to min imize losses at dredge. 2 Utilize eross-ccnnaution with city of Troy water syitwu Privets Drinking Utter Halls 1 NJE Department of BivirotuanLal Conservation will -------------------------------- innartiately. provide....... .... alternate water supply. Hater Treatment 1 Increase polymer dosage Plant Effluent rate at water treatment plant. 2 Initiate polymer feed in ccntaiiment cell overflow weir. 3 Reduce cuttezhead REM, puiping rate and swing speed to mintiirlTs shear forces and dsrresse over flow rates at watar treatment plant. VH-10 HONS 009652 Table 4 - Contingency Options fttvirwuauLal Ccagcnant - Air Target Gontairnent Sit* PEPP 1 Description Increase polymer dosage rate at water treatment plant. 2 _ Initiate polymer feed in containment all overflow weir.__ . 3 Reduce cuttarhemi RPM, puiping rata and swing speed to minimize shear forces and + over* . flow ratas at water ----------------------------------treatment-plant:------ ChloadingArea Dredge 4 Apply PoMlared Activatad Carbon (FAC) to water surfaces. 1 Limit nuttier of ir**mA barge* in area.. .... 2 Cover all barges to reduce 'volatilization. 1 Altar filling procedures to minimiza surface area of aentainmant sediment. VII-11 MONS 009653 Buckley, E. H. 1981. Testimony presarrtad to Industrial Hazardous Mate Siting Board, Hudson Falls, New Yack. Malcolm Pirnia, Inc. 1978. Fusibility Report, Dredging of PC3Qstaainatad River Bad Materials, Upper Hudson River, Haw tack. Prepared for Hew York State Dapartmant of &tvirormental Conservation, Albany, Mae York. Malcolm Fiznia, Inc. 1980. Draft Bwixoroental Inpact Statamant, F9 Hot Spot Dredging Program, Upper Hudson River, Haw York. Psapared for Mae York Stata Dapartmant of Bivironaantal Conservation, Albany, Mae York. New York Stata Dapartmant of Stata. 1980. Official Coapilation of Codas, Allas, and Regulations. lanz and Raicher, Inc., New ______ IS?* o'Brian mi Gars Engineers, Inc. 1982. Budaon River water pcb ttaatSbillty Study. Prepared far Maw Ydrk Stata Dapartmant of Bwizonmntal Conservation, Albany, New York. Cbltad States Department at Hsalth, Education, and welfare. 1977. Qeitaria for a reccnnandad standard.. .occupational exposure to PCBa. CREN (NX06B) Publication Mo. 77-225. Unitad States fiivircnnantal Proleul Irn Agency. 1981. Draft awiLBHMBtal Inpact Statsaant an the Hudson River PCS Raclmaaticn Brensexatlon Project. OSEEA, Region II, New York, New York. _ " ' Walpole, R. E. and R. H. ttyars. 1972. Probability and Statistics for Bigineers and Scientists. Bie McMillan Co., Mew York. HONS 009654 APPOSIX A. laquoac for a Proposal: Volatilization of polyehlorinacad liptaanpla (FCI<) Proa Coataainatad Sadinane* and Vatar HONS 009655 A. Statement of Problem The Bud mo liver PCS lactarnation Demonstration'Pro jaet is a federallp funded project proposing so dredge and encapoulact liver sediments contaminated with PCls. During che raaovel and atoraga of .naarip ona aiilion cubic yards of sediment, vbieh eoncain an estimated 137,000 pounds of PCI, naarip 40 aeras of contaminated sadiaane and uatar will ba exposad co eba atmosphere. Paat raaoarch on cha bahawior of Pels'(Doakay and Andran, 1981; Pal ac al., 1980; lalaaa and Ialmas, 1979; Pawlou and Doxcar, 1979; Paris ac_ al.. .T97F) indieataa ebat cha pocantial for volatilisation from watar and sadiaant hald at tha eonCaiiment aita should bo serioualp axaiaad. Thasa studios also demonstrate that tha measurements and modality of PCI floe froa watar and sadiaant are coaplax. It is iaportaat, nonetheless, to bo able to pradiet the dispersion of PClo froa tha coataiaMsc site to daearaiaa whether its operation will bo in eoaplianea with health and anwiroiaantal- standards and whether tha iaplaoantation ef eontiogencp measures should ba eonsidarad. Uorh bp loeklap (1980) indicates that plant PCI eontaaination above PSA Units eould oeenr in this araa adjaeant to tha eontainoant site. The projection af crop losses is daairad to ainimiaa tha disruption of faming. Uhila tha PCI ness mission rata to the ataosphere is perhaps tha aost critical information for such as aaalpsis, it is prasentlp tha aost difficult co aneuratalp assess. 1. Background Data currantlp available far evaluating cha flux of PCls froa water and sadiaant are spar so. Although solubilities of tha various PCS isonars and comertial mixtures have boon dataraiaed, vapor pressure data era available for snip a few isaears and che Aroclor aixturaa (Destcott and Bidlman, 1981; Mwmhr at al.. 1981; Mackap at cl-., 1981). Volatilisation of various Aroclor mixture's-from water and from-?cFcoucinated sadiaant a was measured in laboratorp tank casts (Hading at jd., 1978), and tha results of these studies have been used to estimate the Tosa and dispersion of PCSs from cho eoncsinmonc oitt (Maleolm Urnis Iae., March, 1981). These predictions are based upon data from aa experiment using s saturated aquaoma eolation of Aroclor 1141. Other Aroclor nihturet have been idnatifiad in Hudson liver sediments ss wall (Hollar et al., 1976), and ovor tha 23 paara. chat PCla hove sxiatad in cha andimanta "Individual componenta hove undoubtadlp undergone weathering. Tar che purpose of prodieting looses of PCI at the cencaiment aita, it ia therefore neceoaerp to dacamine float racaa of Che particular PCS components thst curranclp reside ia ledaon liver tadimancs. - PCI concentrations measured in sir samples collected above saveral Hudeon liver dredge spoil disposal aicaa wars diraetlp corralacad vith PCI concentrations in Cho drodgad sediment (Tofflemire sc el_., 1981). At those sitaa average ambient PCI air levels ranged from O.T'co 130 ug/a3 and Mdiaenc coneantrationa wort 10 to 50,000 ug/gm (Tofflesiire st al., 19bl). It ia axpoetad ebae sadiamnts handled is the proposed Hudson River dredging project will average 100 ppm PCI during cho first peer of operation (Malcolm Plraio, Inc., 1980). Doing desorption theory, cho dissolved PCS concentret ions in water hold at tha aita are expected co bo ia cho range of 10-20 ug/1 (DEC, MOhS 009656 2962)* DiToro tnd O'Connor (CS E?A, 2982) have ealeulatad, by relating aediaaeat KJ concentration end the desorption coefficient to the percent volatile eolide in the aediaent, that Che dieaolved KB concentration will noc mated 40 ug/l. The rate of PCB film from the contaminated aediaenta and water at' the contaiment cite will'also be affected by environmental prarametert auch at taeperacvire and wind speed. These factor a will be taken into aceoimt when predicting eoneantrationa of KB at the aice and ita aurrounding area. C. Scope of Bock Experimental The proposed work would result in a means to accurately assess Che maaa amission race of KBs from Che surface of the containnane area throughout the dredging operation. ' Studies should be designed to examine volatilisation processes under conditions similar to those encountered ae the containment aice. It is initially recoaemnded thae Hudson River hoe spot sediments (> SO ppm PCB) bn employed in the studies. The composition of KBs in these sediments should be charascorisod; flux measurement a should bo based on chose interpretations, lolovanc environmental parameters should be considered in the design of the study. Errors associated with varying coilaetion afficianeiaa for PCB cenpouada and with eba uaa of standard Arocler interpretation when measuring PCS volatilixad from Hudson River sediments should bo addrossod. Beta Analysis A calibrated machautical cool for predicting PCB volacil Use inn aa a function of tenperatura, dissolved PCB concentration, sod ocher relevant factors for sodimont/uator mixturos and sot sediment should ho provided, a rational rachar than puraly empirical mathomcical framework is desirad. A final report will bo submitted by June, 1983. . 0. Instructions and Conditions for Preparation of Proposals . If intartsced, after reviewing cbe Scope of Dork, potential contrac tors should submit a proposal to cbo Dopartmant of Enviroiaancal Conservation by April l, 1983. This proposal in addition to clearly outlining cho contractor's proposed approach to the study should include the following: 1. flbat background and expertise does the potential contractor have which he could supply to the project? 2. Cast and pries analysis. Proposals naad not be submitted In elaborate format nor in expensive binders. final taleetion of s contractor will be diecacsd by an evaluation of HONS 00965 7 tho contractor' proposed approach co ebo problem, previous experience in carrying one services of this type, technical azparciaa and knowledge in cha araa, cost and overall management tapahilicy for carrying one cha propoaad work. Criteria co be eanaidarad in the evaluation of reapondenta far subair* aion of prepoaala will include: . 1. Specielined experience and profaaaional competence of the re spondent and ita personnel (including a joint vencure or associ- . ation subcontract) in connection with cha type of services required and the eoeplexiey of the project; ' 2. Past record of performance on contracts with the grantee or with othera, including such factors as control of coats, quality of work, and ability to meet schedules; 3. Special consideration for small and ainoricy businesses; 4. Capacity of the respondent to perform the work (including any specialised services) within the tine liaitationa, caking into consideration Che current and planned workload of cha reapouent; 3. The familiarity of Che respondent with types of probleae applica ble to eba project; and 6. Avoidance of personal and organisational conflicts of interest prohibited under State and local law. able: In preparing the proposal, the following conditions will be accept 1. If a potential contractor feels that different approaches and/or additional work would be desirable, he should describe and quote them. 2. Specific rigid, detailed tine schedules will be required. 3. All equipment purchased with funds to carry out the project will become ehe property of the Federal govemuenc at Che completion of the project unless otherwise specified. 4. The potential contractor should indicste tho manner in which eha data mould be reported! Ibis Inquest for Proposal does not eoamit the hew fork State Departmeat of Environmental Conservation to award a contract, to pay any coat incur red in the preparation of a proposal to this roquoae, or to procura or contract for services or supplies. The Department reserves the righc to accept or reject any or all proposals received es a result of this request, to nagotiata with any qualified source, or to eancal in port or in ita entirety, this ITT, if it is in tho hose interest of cha Department to do so. The Dopartaont nay roquire the offerers selected to participate in negotiations and to submit such price, technical or other revisions of their proposal as nay result from negotiations. HONS 009658 toy contract awarded under thia (invitation for bida or raquaac for 'qualifieationa/propoeala) ia aspect ad to bo funded in part by a (rant froa the United Statea Environmental Protection Agency. Thia procurement will be eahject to regulariona contained ia 40 C7K Subcbapter B, and particularly Part 33 thereof. Neither the United Statea nor the United Statea Enviroiaental Protection Agency ia nor will be a party of thia (invitation for bida or . raquaac for qualifieationa/propoeala) or to any raeuleing contract. / HONS 009659 Literature dead Bucklay, I.l. 1910. PCBs is vegetation. Sore* Thompson Institute far Plane la March, Ine., far 5T3 Department of Eavironnaneai Conservation, Albany, it. . Doakey, P.7. and A.I. Andran. 1981. Hodeling eha flux af atmospheric palyehlerinatad biphanyla acroaa eha air/wacar interface. Environs. Sal. Taehnol. 13(6) :703-711. lading, I... I. Hern, and J. Tofflanira'. July, 1978. Suanary of Budaon liner KS atady resales. Taehnieal Paper #31. ITS Department of Envirooaentai Censervstion, Albany, l.T. ' silax, T., l. It. Plaaaaat, S. Pagano, J. Spagnoli, and H. Stasiuk. March, 1978. PCS data in Sudaon Hear fiah, sediments and uaateweter. STS Department of Enviranancal Conservation, Albany, S.T. Kalaaa, 1.7. and S.D. lalaaa. 1979. Transport, distribution, and tosie affecta of polychlorinated biphanyla in ecosyaeaaa: a review. Seal. Modalling 6:223-231. Maekay, D., S. Patarson, W.T. Shis, A. Bobra, and J. Billingcon. 1981. Physical chamieal propertiaa and behavior of PCSa. laport presented at workshop on Aysieal Behavior of PCBs la the Croat Lakes, Toronto, Ontario, Decsober 10-11, 1981. Males la Pimia, Ine. SeptMhar, 1980. PCI hoe apot dredging progrs upper ladtan liver, lew Tork. Draft Eavlronamntsl lapact Statement, STS Environ mental Quality levies. Prepared for ITS Department of Xnvirenoeatai Conservation, Albany, IT. Malcolm Plrnia, Inc. March, 1981. Stansry of PC3 volatilisation rats * estimates and iapact predictions. Corrsapondancs to l.f. Thomas froo A.M. tear. ' Morphy, T.J., J.C. Pokojowcsyk, and S. Paollueei. 1981. Banry'a Lav Constanta froa equilibrium auusuramusts; larga psrtienlataa in PCS dspoaition. Ispert prasantad at vorksbop on Physical Bahavior of PCBs in eha Croat Lakaa, Toronto, Ontario, Docanber 10-11, 1911. ITS Dopartaont of Znviroameneal Conservation, August, 1981. Isaponaa to beeutlva Sianary of Draft Znviroomuntal Iapact Statement. ITS DEC, Albany, IT. . Pal, D., J.B. Weber, and M.l. Ovsreaah. 1980. Fata of PCBs in soil-plant ayatsaa. taaiduo lovitws 7A:A8-97. Paris, D.T., W.C. Staan, and 6.L. Baugbas. 1978. Sola of physico-chmaical properties of Aroclors 1016 and 1234 in determining chair fata and transport in aquaeie savironnsnea. Chsmosptaere 4:319-123. HONS 009660 Literature Cited (eon':) Pavlou, $.P. and R.H. Dexter. 1979. Distribution of PCS in astuarina ecosystem*. Tasting tha concept of equilibrium partitioning in the aarine environment. Environn. Sei. Taehnol. 13:63-71. ' Tofflamire, T.J., T.T. Shan, and .H. Buckley. 1981. Volatilisation of PCS Proa sediment and aatar: experimental and fiald data. Report prtaoncad at workshop on Physical Behavior of PCSa in tha Croat Lake* hold at Toronto, Ontario, Secanbar 10-11, 1981. / ' U.S. Environmental Protection agency. Hay, 1981. Draft Enviromaeacal lapact Stataaant on tha ladson River PCS Reclamation Daaonatration Pro:act. OSZPa, Region II, Mav York, SY. Hesccoct, J.U. and T.F. Sidlman. 1981. Determination of PCS vapor praaanra by capillary gas chromatography. J. Chrom. 210:331-336. MONS 009661 tntniX I. laquast for a Proposal: Salaaaa of Polychlorinactd Bipfaanyl (PCBa) frea Coneaaiaatad Hudson livar Sadiaanca HONS 009662 A. SUtmnt of Problem During 30-yeer period ending in 1977, over 300,000 poundn of polychlorinated bipbsnyls (PCBs) ware released into the TJ^per Hudson Hiver. Sesults of extensive sampling conducted aver the put fit* years indicate that more than >i tha dis charged aasa of PCBa remains is the 200-cdle downstream portion at tha river (MFI, 1980)> Analyses of vater and sediment aaaplea (Tofflemir* t al., 1979; Hetling tt al., 1978) demonstrata that had sediments, which vara a major sink for FCBs daring tha discharge period, presently act aa the aajor source of iCBa into the water eoluan. la order to reduce tha contribution of FCBs-from bottom materials and to mitigate tha adverse impacts of preaant levels of FCBs ia tha Eudson Bivsr water eoluan, tha Haw Torts State Departaeat of Zarironaontal Conservation (5TSBEC) pFOpOtM to dredge and encapsulate a portion of tha PC3-eemtaaiaatid sediments (MR, 1980; US EPA, 1981). Tha project, aa currently proposed, would reaoea apjruxinetely one-third of the PCB contaminants; tha remaining PCBa will be subject to natural removal processes. ' Aa investigation of tha mechanisms which determine how PCBs are released --tram Budaon Xivar sediments is required st this time ia order to more accurately define bad sediment/water interactions affecting FCB transport and thereby aecsmaodate an assessment of the long-term response of river recovery after dredging. B. Background Previous hydrological studies consisting of three years of aaslytieal data amt flow seaonrsmanta at three stations on the Hudson liver indicate that release asd --p"-* of PCBa from bad eedineuta are flow dopondont. Minima levels of Rln wore detected in water samples collected during intermediate river discharge rates (**00-800 afoee), whereas FCB ecneentrmtioua rose from sinimua valusa with both inereasiag asd decreasing discharge rates (Turk, 198O; MR, 1980). Two msilianl ass for PCS relaaoo from sediments with respect to flow bars boon suggested: ' '_ ' (1). Soring low flew, FCBs in the water eoluan are primarily in tha its solved phase, sad their concentrations are determined by nearly _ constant rates of desorption from asd sigratien through sediment saterials. (2) During periods of high flow, PCBa are transported in the water column sorted to asterials scoured or eroded from the river bottom. Although the data support s flow-dependent relationship, other environments! parameters such es sediment characteristics must bs considered in FCB release sad transport mechanisms. Adaorptlnn/dcsorptlon phenomena have been related to pariiele tine and organic eontant as wall aa othar physico-chemical characteristics of natural sorbent systems (Brown and Flagg, 1981; O'Connor and Connelly, 198O; Kenagaand Soring. 1980. Favlou and Dexter. 1979; Faria et_ el., 1978). As hydrophobic compounds, PCBs have 1 strong* affinity for partielss which are small and therefore possess large surface to volume ratios and for organic materials that possasa strong heeding capabilities. Sediment grain size and organic content have been, related - to FC1 eonetetretions in Hudson Hirer sediments. In the Hudson Hirer, FC3 enc-entratlnr.s are generally highest ia silty sedimentj, moderate is coarse sand with MOMS 009663 1 woo* ehipa, ad lowest la sand sad gravel with se organic natter (Tofflemire jllL., 1979). ! Whereat partitioning of PCS* haa been examined In adsorptive processes, ; little attention has been given to desorption from natural sedinents. Salter' j and Johnson (1977) used a nodal aquatic system incorporating sediment, water, sad fish components to neasure the dynamics of Aroelor 125b under both flowing I and static conditions. Wildish a al.(19fl0) examined the desorption of Aroelor i 12Jb froa various particle size fractions of sedinents in continuously shaken eantrlfugs tubes. These and .other studies (Tofflenire at el., 1979) indicate . that experimentally derived partition coefficients, which range froa 103to 103 ug/k^ug/1. nay be highly dependent upon the nethods and natarials used. Zroaional characteristics of the various., types of sedinents found in the Ssdaon Biver play an important role in the transport of particulate-associated KBs. The rate of eroaion end transport of nen-eohesive sediment materials My be readily predieted, but parameters influencing the relative credibility of cahtsivt nsttrials, which are generally sera highly contaminated with PC3, are not well understood. Sueh properties as naan particle size, percent clay, plastlelty index, and dispersion ratio nay be used in an attaapt to predict eroaion rates of cohesive aedinenta, but field and laboratory measurements are considered sore reliable (Sottsehalk, 196b). Preliminary laboratory fluaa stadias have been conducted on credibility of cohesive sedinents collected from the Budson Biver (Ziaade, 1961). A PCS transport sodsl for the Hudson Biver has been developed which is designed for non-cdhealve eediaent transport (IMS, 1978, 1979), Bower**, the ~neiel does not tddrese erosion of fine-grained sedinents, sueh- as silt and clay, aar dees it diacrladnate between aqueous and sorbed PCBs. In order to sdre accurately depict the transport of PCBs, a rational soalyals of the processes that contribute to eedisent/weter PCS intermetions, including desorption fins end erosion of both eehealvo and non-cohesive aedinenta, is required. _* C. Scone of Work fctaerimental ' The proposed work would result in a means to accurately assess the disposition of PCBs between contaminated bed sedinents and the water coluan in the Hudson Biver. Studies should bo designed to experimentally relate deaorptive and eroslonal processes as a function of flew rate sad sediaent characteristics. Coasldaration should be given to variables known to affect FCB study results such as temp erature. suspended solids concentration, end adsorption of PCBs on walls of experimental apparatus. It is receoMnded that a variety of Hudson Biver PCB-contamiaated sedinents be enployed in the studies. Thase should be characterized with respect to grain else, organic content, end PCS content. FCBa should be analyzed by standard Aroelor interpretation end by identification of individual components-. Depth HONS 009064 profiles of sediment samples, using the lattar netted, should parol': aaaaasaast of PCB weathering. Aquaoua samples will be analyzed for diaaolTad aad partieulateaaaeelatad FCBa. Oita Analysis . Attention must ha given to pro-riding a rational mathematical daaerlption of PC3 ralaaaa*. Classical hydraulic parameters which would isfluanea tha application of tha study raaulta should ha defined. Problems aaaociatad with sealing of tha experimental system should ha aeeeustad for in data interpretation. A final report will ha submitted by June 1, 1943. D. Instructions and Conditions for Preparation of P-o,""i - Potential contractors should aubait a proposal to tha Department of ferlronaeatal Conaereatlon by June 1, 1942. This proposal Should include tha fallowing: 1. Proposed approach to tha study; 2. Background and expertise of the potential contractor; 3. Coat aad prlee analysis. Pinal selection of a contractor will ha dictated by an eealuation of the ssatraetor's proposed approach to tho prohlas, previous experience in carrying mt services of this typo, technical expertise aad kaowladge in tha ares, east, aad overall aaaagesent capability for carrying out tha proposal work. Criteria .to h* considered in the evaluation of respondents for subsiaaion of proposals will include: * . 1. Specialized experience and profaaalonal competence of the respondent sad its perseaasi (including s Joint venture or association sub contract) is connection with tho typo of services required aad the complexity of the project; 2. Pest record of performance on contracts with the grantee or with othora. Including such factors as control of casts, quality of work, aad ability to soot schedules; Capacity of tho raspeadaat to perform tho work (Including any specialized services) within tha tins limitations, taking into consideration tho currant and planned workload of the respondent; A. Ihe familiarity of tho respondent with types of problems --1' -ble 'to the project; 3. Special consideration for small and minority businesses; and i. Avoidance of personal sad organization conflicts of interest pro hibited under State snd local law. HONS 009665 In preparing the proposal, the following conditions will apply: 1. If a potential contractor feels that different approaehaa or additional work would ha daairmbla, ha should describe and quote than. ' 2. Specific, rigid, detailed tine achadulas are required. ' 3- All equipment purchased with funds to carry cut the project will become the property of the federal government at the completion of tv, 1 project unless otherwise specified. A The potential contractor should indicate the manner in which the data would be reported. This Bequest for Proposal (STP) does not commit the Sew fork State Department of Zneirenaeatal Conservation to award a contract, to pay any coat incurred in the preparation of a proposal to this request, or to procure or contract for services or supplies. Bie Department reserves the right to aceept or reject any or all proposals received as a result of this request, to negotiate with any qualified amorce, or to cancel in part or in its entirety, this DTP, if it is in the best interest of the Department to do so. The Department may require the offerers selected to participate in negotiations and to submit such price, technical or other revtaiona of their propoaal an nay result from negotiations. Any contract awardod under this (invitation for bids or requoat for qualiflcntionn/propoaals) in expected to be funded la part by a great from the United States Ssrlroamemtal Protection Agency. This procurement will be subject to regulations contained in *>0 GX Subchapter B, and particularly Part 33 thereof. Neither the United States nor the United States Zhvirounental Protection Agency in nor will be a party of this (invitation for bids or request for qualifications/ proposals) or to say resulting contract. HONS 009666 Literature Cited Town, 0- S. and E. V. TlAgg- 19fi1. Empirical predictions of organic pollutant sorption la natural sediments. J. Ensiron- Qual. 10(4): 382-386. Settschalk, L. C. 1964. Sedimentation. In Handbook of Applisd Hydrology, Van Is Chew [ed.l. McGraw-Hill Book Co., How fork, N.T., pp. 17-1 to 17-34, kitor, M. T. and H. S. Johaaoa. 1977, A nodal system to atudy the daaorptloa T.aad biological araliability of PCS ia bydroaoila. la Aquatic Toxicology and Bmaard Eealuation, ASTO S7P 6*4, L. Mayor aad J. L. Sanaliah [ada.I . American Society for Tasting aad Matarlala. - latliag. L. X. Bora, aad J. Tofflemire. 1978. Summary of Budaoa Biser PCS Study Hanoita. Technical Paper # 31. NTS SEC, Albany, N.T. Eaaaga, Z. E. aad C. A. I. Soring. 1980. Belatlonship between water solubility, sell sorption, octaaol-watar partitioning, aad concentration of ehealeals la biota. Ia Aquatic Toxicology AS1M STP 707, J. S. Eaton, P. B. Parrlab. and A. C. Kaadricks Cads.], Aaaricaa Society for Testing Matarlala, pp. 78-113. Jtnwler, Matuaky, aad Skally Engineers. 1978. Upper Sudacn Kiser PCS Action Alteraatisa Study. Pinal report to NTS SBC, Albany, H.T. lawlsr, Metuaky, aad Skelly Eagiaeera. 1979. Upper Budaoa Kiser PCS Transport Modeling Study. Pinal repost to IRS EEC, Albany, N.T. Malcola Plxnie, lac. 1980. PCS Bat Spot Dredging Program, Upper Budaoa, New Took, Draft Ensironaantal Impact Statement prepared for NTS DC, Albany, H.T. O'Connor, S. J. aad J. P. Coaaolly. i960. The effect of concentration of adoorbiag solida on tbs partition eoeffleiaat. Hater Bee. 14: 1317-1323. ksla. D. ?.. W. C. Steen, and 3. L- Baugfaaa- 1978. Bela of physico-chemical properties of Arodora 1016 and 1234 ia determlaiag their fate and trans port ia aquatic aasironoanta. Cbaooaphara 4r 319-323. _ kslou, S. P. aad 1. N. Sartor. 1979. Distribution of polychlorinated biphenyls (PCS) ia eatnarlae ecoeTirana. Tasting tba eoneopt of equilibrium partitioning ia tha aoriaa environment. Snslroa. Sei- aad Teohnol. 13(1): 63-71. TofGaarijra, T. J., L. J. Batliag, aad S. 0. Quinn 1979. PCS ia tba Upper Budaoa Bisar: Sadioant Diatributiona, Watar lataraetiona, aad Dredging. Teebaieal Paper i 39. NTS DEC, Albany, N.T. Turk, J. T. 1980. Application of Budaoa Biser baaia FCS-traaaport studies. Ia - B. A. Baker ted.] , Ceataadaaata aad Sediseata, Vol. 1. Aaa Arbor Science, Ana Arbor, MI. IS EPA. 1981. Environmental lopact Statement on the Hudson Riser PCS Reclamation Demonstration Project. US EPA, Region II, New Tork, N 7. MONS 00966? Zlanio, T. .1981. Dotornininf Ht. of Coh.siv. Sodinont Erosion for th. Hudson Hl7r. final rrpcrt to TO ISC, Albany, H.T. HONS 009668 AFPUWU C. Fiih Praparacion Procaduros for Contaainane Analjtii MOWS 009669 Hew York DEC conduct* studies requiring chemical analysis on flab tissues. Routine nonicoring and surveillance studies develop data on ceneaminancs in fish lor several reasons: 1. To identify sources of environmental contamination. 2. To Identify Hie seoRraphie extent of environmental contamination. 3. To Identify temporal trends of eontaainanes in fish and wildlife. A. To provide Informer Lon- rupardin* liumen conaiusption advisories. Oiemicsl analyses of edible fish flash have been determined to be the nose appropriate analyses for satisfying ail of these objectives. The following methodology has been developed in order to standardise the tissues under analysis end to adequately represent the contaminant levels of flah flash. Tha methodology is slightly modified from the U.S. Food and Drug Administra tion procedures. The portion of edible flesh analyzed will be referred so as the standard fillac unless otherwise noted. For soma species,, the pro cedure is modified as indicated below. Procedure for Standard rillecins 1. Kamova scales from fish. Do not- remove Che shin. 2. Make a cut along the vaneral midline of tho fish from the vent to the base of the jaw. . 3. Make diagonal cut from base of eraolum following Jose behind, gill to the ventral side Just behind pectoral fin. 4. lamove tha flash and rlbcaga from ooe-half of the fish by ' ' _ ' cutting from the eraniias along the spina and dorsal rays to ' ' the caudal fin. Tha ribs should remain on the fillet. __ '3. Score the skin and homogeniaa the aneira fillet. Modifications to Standard rillet Foot modifications of the standard fillet procedure era designed to account for variations in flab size or known preferred preparation en eetbods of the fish for human consumption. . 1. Some fish are too small to fillac by eha above procadura. flab lass then approximately 4 Inches long and rainbow sawIt are analysed by cutting tha head off from behind the peetorsl fin and.eviscerating the fish. Ensure that the belly flap is retained on ehe eareses to bo analysed. Whan this modification la uaod, it should be noted whan reporting analytics! raeulcs. ' HONS 009670 2. Souk species are sanerally taean by skinning cha fish. The akin {ten tluute species U also relatively difficult to homogeniza in cha saoiple. Monro, for Clio following llac of species, cha fish la first rtllnmrtl |'cLir lo illloting. Brown billhead Tallow bullhead Atlantic a curjeon Black bullhead White catfish Channel catfish Lake sturgeon 3. Aaarlean ael are analysed by renewing the head, skin, and viscera; filleting la nec attempted. 4. Forage fish and young-of-year fish are analyzed whole. This eacagery la considered to be leaa chan 130 on (6 Inches). HONS 009671 c-z APPENDIX B PRE-DREDGING SEDIMENT SAMPLING PROGRAM MOMS 009672 B-i APPENDIX B PRE-CREEGING SEDIMMT SAWUNG PROGRAM General Hie Pre-Dredging Sediment Sanpling Program Is being developed consistent with the following objectives: a) Advance the knowledge of the PCB distribution in sediments in the upper Hudson River b) Assess the mechanima controlling the redistribution of sediments in the upper Hudson River (e.g., velocity profiling and measurement of sediment credibility). The details of the sediment sampling program are presently being developed by D0C. In concept, the program will consist of the following basic eleaents. 1. Review of existing PCB sediment data and sediment texture. 2. Review of existing fathemetry and hydrology to initially assess river areas of high velocity and possible scour and deposits. (Wetlands will also be considered). 3. Development of grid work far the river. 4. Establishing horizontal and vertical control networks for hydrographic survey and fathemetry, respectively. 5. Purchase and aet up hydrographic survey equipment, boat, and ooring equipment. 6. Establish data management system axnpatible with the DEC project laboratory output. ' 7. Submit work plan and report by April IS, 1982. 8. Initiate field saspling program. " ' 9. Apply data to simplified sediment transport schemes to verify and possibly modify areas to be dredged. Sediment sarnies will be collected by DEC utilizing a vibra core, location of the cores will be satsbllshsd utilizing the hydrographic survey system being developed specifically far this project. As aores are collected, CBC engineers and scientists will visually inspect the cores and will reccisimnd appropriate sectioning. The cores will then be sent bo the EEC project laboratory where they will be analysed for PCB. Selected cares will be analyzed for metals, 137cs and Pb. The laboratory data sheets developed by DEC for use in the lab are contained in the QA/QC docvment developed as part of this project. The B-2 HONS 009673 laboratory has been established for this project to assure timely ocspletion of the analytical work such that data will be available under very tight tine con straints. As the sediment data beocnes available, data analysis will be initiated. The ultimate goal of this sanpling effort is to prioritize most critical and cost-effective areas to be dredged under the full scale and reduced scsle project. In developing the dredging plans and specifications, the specific areas to be dredged will reflect the information gathered during the 1982 sediment sailing survey. Preliminary criteria idiich msy influence these decisions are (a) areas of highest concentration or greatest easa, (b) areas susceptible to scour or deposition under various hydrologic regimes, (c) areas disturbed by navigation and td) areas of desorption. Item D above will be developed in more detail following the results of the study entitled PCB Release froai Hudson River Sediments being performed by the University ot Michigan as part of the Step i Grant for this project. B-3 HONS 009674 APPENDIX C IETTER. FROM NYS SOLICITOR GENERAL HONS 009675 C-l IV ** Stats or Mw Yokk Department of Law Alsaxy. N. Y. laaaA October 23, 19SI Bon. Robert T. Flacke Commissioner New York State Department of Environmental conservation iO Wolf Bead Albany, Hew York 12233 . Dear Commissioner Flacke: The Kew York State Depamant of Environmental Conservation is undertaking the Hudson River ?C3 Reclamation Demonstration Project, whereby PC3 sediments will be dredged from the rives in Washington and Saratoga Counties and, after treatment, buried in a containment facility. Your civil counsel has asked whether these are activities for which the State has waived sovereign immunity under section 8 of the Court of Claims Act. ' - Through the waiver of immunity effected by section 8 of the Court of Claims Act, the State is liable for the torts of its agents on the basis of respondeat superior, notwithstanding the fact that the agent is engaged in a oovemnental activity (Jones v State of New York, 33 NY2d 275, 230 [1973]). It has been decided that the State can be held liable for its negligent acts in carrying out a governmental plan (Keilyv State of New York, 57 AD2d 320 [4th Dept, 1977]). Generally, as a landowner, the State has a duty not to use its land in* a manner so as to cause injury to neighboring property owners (Palmer ltd, v State of New York, 33 AD2d 412 [3d Dept, 1970]; Poysa v State of New York, 102 Misc 2d 2S9 [Ct of Claims, 19791) 6: course, for the State to be liable in negligence, the plaintiff must be a person to whom a duty is owed and who has suffered injury'or damage (Motvka v Citv of Amsterdam, 1! NY 2d 134 [1965]). C-2 HONS 009676 2. W conclude tiiat the State can be held liable through suit in the Court of Claims for any ne<;li<jent or ether tortious acts of the Department of Environmental Conservation ccreitted in carrying out the Hudson River ?C3 Reclamation Demonstration Project. Very truly yours. Solicitor General C-3 HONS 009677 APPENDIX D Simnary of Cultural Resource Survey Result* far Site 10, Hudson River Reclamation Project Smeary prepared by Nee York State Department of Environmental Conservation, Albany, New York, August 1982 D-l MQNS 009678 CULRJFM. PESOUICS StMABX: In oorfozmnce with federal and state laws and implementing regu- laticns far the protection of historic and cultural properties (Draft EIS, Ms/ 1981: 3-40 to 43; Supplemental Draft EIS, August 1981: Appen dix B-l), additional evaluation and docunentatLon for consultation was necessary on resources identified in the Stage 1 cultural resource survey (NXSCEC Septanfcar 1981: 8-1 to 3; Table 8-1). Further investigations of identified resources ware designed to provide the data necessary to evaluate the potential eligibility of historic and archaeological proper ties for listing on the National Register of Historic Places. Consultation with the NYS Historic Preservation Office (NYSHPO) focused on the evaluation of eligibility to the htional Register of all historic structures and archaeological sitae located within the proposed containment site (Site 10) boundaries and the "Vlctcrian-styla" house located nearby. The EPA's proposed projact impact on the Old Chaaplain Canal, a property listed on the National Register of Historic Places, required special con sideration through consultation with the Advisory Council on Historic Preservation (ACER). In accordance with ACHP regulations (36 CFR 800.13 a), the EPA determined that the proposed pipeline crossing of the canal would have no adverse effect on this property. The construction corridor will be limited to a disturbed segtent of the canal. Protection of the rmwinlnrj canal within the project area will be enforced. The JCHP, in their letter of January 15, 1982, did not abject to EPA's determination pending the outcome of EPA's planned further investigations (Stage 2) and evaluation of resources identified during the Stags 1 survey. Die ACHP the condition that the nearby "Vlctorian-style" house be evaluated for its D-2 MONS 009679 potential to mat the criteria tor listing on the National Register. Hie EPA has complied with the ACHP oondi t.ions Hie EPA, in consultation with the NXSHPO, has concluded the following: All, resources except for Site 1 (Hudson South), do not neat the criteria tor listing on the National Register of Historic Places. Sits 1, an identified prehistoric deposit will be protected free currently planned and future construction activities. Site 1 is located in a buffer zone of the project area. Hie Dead Creek bank, an area identified as a sensitive ar chaeological zone during Stage 1 survey, will be protected in a buffer zone of the project property. Hie structural elanents of the nineteenth century barns will be offered for salvage a.) to a recognized individual or groq> that will utilize the materials for historic recon struction projects; or, if no qualifying party can accept the materials b.) the barns will that be <W.nhi by the project construction contractor. According bo the no adverse effect determination approved by the MSP, proposed pipeline construction will be restricted to a corridor that will be fenced during construction. Hie northern sapient of the Qeeplain Canal within the project area will be protected from impart. _ Hie smeary below describes the results of the Stage 2 investigations and EPA's consultation with the 1USHP0 concerning the resources investi gated. Table 1 smmrizes and updates the recommendations for all resources identified during the Stags 1 (Table 3-8 of the Draft EIS, May 1981) and the Stage 2 surveys, and the results of EPA's consul tations with the NYSHFO and the MSP. Sunnary of Stage 2 Investigations: Tb provide data far an abjective evaluation of identified resources, NXSCBC contracted with Hartgsn Archaeological Associates for a Stags 2 cultural resource survey. Hie following cultural resources were investi gated (site designation in parentheses appeared in Table 3-8 of toe Draft D-3 HONS 009680 EIS): Sites 1 and 4: prehistoric archaeological deposits (Hudson South and Hudson North) Sites 3, 5 and 6: historic archaeological deposits Site 7: two nineteenth century bam structures (Old bam aoaplex) Site 2: farm water system (foundations 1 and 2). Sitae 1, 2, 4 and 7 were identified during the Stage 1 field investigation. The historic archaeological sitae (3, S and 6) were identified during the Stage 2 investigation. All resources, except the two bam structures, are located on the Site 10 property east of the Hudson River and west of the Old Chanplain Canal which parallels ms Route 4. The archaeological sites were investigated by controlled, systematic subsurface eaujl luj consisting of shovel tssts at regular intervals, cnemater squares and trenches. Information concerning the age, cultural mffi HiHm and lntetgrity of the prehistoric and historic archaeological deposits was obtained. Mbrk cn Site 2, two fwmJations of stone and con crete connected with a vanII diaseter pipe, concentrated an determining the function and associations of this system. An architectural study of the two bam structurea wma directed at ascertaining construction date, integrity and architectural significance. The foilwing smeary derives fzan the detailed Stage 2 cultural resource survey report (Hartgsn Archaeological Associates, February 1982). 1. Prehistoric Resources! Sits 1 (Hudson South) : Lata ArCheic/Middle bo Late Vtoodland Periods (approximately 2000 BC - 1500 AD) interpreted as a lithic manufacturing and hide preparation area; possible stratified deposits with intact features. The site is located within a buffer zone of the project area 0-4 HONS 009681 which will be fenced. Impact will be avoided and, therefore, no further consideration is needed. Site 4 (Hudson North) : Late Archaic (approximately 2000 BC) repre sents a food processing area. Twj hearth features were identified; one within and one below the plowacne. The integrity of the site has been caipeamised and no further study is reocnmanded. 2. Historic Resources: Sits 2 (Foundations 1 and 2): aoncrete and stone foundations corrected by a small diameter pipe interpreted aa a farm water svpply systaa opera tional from 1910 to 1952. These recent features are adequately docaeantad in the Stage 2 survey. No further study is recu;unaided. Historic archaeological deposits constitute the remains designated as Sites 3, 5 and 6. These deposits consist of distinctive, but spatially small concentrations of kitchen and architectural imperials. The context of these three archaeological deposits wars compromised by erosion, flooding and plowing. Site 3 represents a short tern occupation during the last half of the eighteenth and early decades of the nineteenth century. No structural remains ware associated with the artifactural materials. Site 5 consists of material adjacent to a drywell field stone and bride feature along the riverbank. The structural remanent is located in the vicinity of a building of unidentified function recorded on the 1830 NTS canal survey for this area. Analysis of the archaeological material indicates a lata eighteenth to early nineteenth century date for this deposit. site 6 consists of an early to mid-nineteenth aentury archaeo logical deposit. The deposit may have been associated with a structure of tmidantified function recorded on the 1830 NTS canal survey map fer the area. The structural remains have bean destroyed by a boat lainch and access road within the project area. All of these historic archaeological remains have been adequately D-5 HONS 009682 doozsntad in the Stage 2 report. No further study is reoooamndad. Site 7 two mid-nineteenth century boms. These boras represent typical structures of the Hudson Valley. These types of structures are well represented within the region. The barns are not associated with a particular farmstead or builder. Architectural doctmentation of the barns is provided in the Stage 2 survey. No further study is reocmnended. "Vlctorian-styla" house: The Stage 2 survey provided the following information on the house: 1900, approximate date of construction; builder, Irving Bristol; Owner, Hattie Bristol. The land was owned by Luther Pike until 1893, when it wee deeded to his daughter Hattie (Mrs. Irving Bristol) Pitas. The integrity of the house has been ocnpronised by structural modi fications and it is tha O'A'a opinion that the structure is not National Register eligible. Conclusions: Tha EPA and NKSHPO have evaluated the resources in the project area and have consulted on the potential eligibility of the resources to the National Register of Historic Places and the potential effect of the project on any resources meeting the criteria for eligibility. The EPA has crww-lirffi that tha project will not affect resources an or eligible to the National Ragistar, other than the Old Oaaplain Canal. The EPA will mitigate the project effect to Old Chanplain Canal, a property included in the National Register, by strict adherence to their docu mentation of no adverse effect as approved by the Advisory Goimcil for Historic Preservation. HONS 009683 0-6 Tabu Sutwary of Cultural Rtaouccu t iii near sits 10 Cultural Resource A opinion SWO cftnicn old Chanplain Canal, National fegiaber Property* No Adverse Effact (correspendanoa <*ted** Decanter 9, 1991, January IS, 1992 and August 11, 1992) i. TUo nineteenth caneury bams, Site 7 (old barn cooplax) * toe National Ragiitar eligible (ITIS) 3. Prehistoric archaeological Site 1 (Hudson South)* Sita protaction; sita not in project ixpact araa (FEIS) 4. Prehistoric archaaological Sita 4 (Hudacn North}* tot National Ragiatar eligible (FEIS) Historic archaaological deposits, .Sites 3, 5 and $ tot National Register eligible* (FEIS) a. Victoriaiy>acyU houaa Not National Ragiatar eligible (FETSJ T*neie*h cantury farm water <y-.tro, Sita 2 ;o*j stone and concrete foundations)* toe Netionel toglstar eligible ircis) <1. tv iventieth caneury duep sitae .Historic <hnpa l and 2)* tot Netionel Ragiatar eligible (TCIS) 9. Hudaon valley Railroad Mgnnt* Not National Ragiatar eligible (FEIS) Oaad Crack bank pcahistoric Araa protection; araa not in sensitive ora* project infect araa (FEIS) concurrenew (correspon dence detsd** October 29, 1991) tot National Roister wLigtbl* (August 4 , U82) to need to evaluate tangi bility (August 4, 199?) tot National Aegistm eligible (August 4, L992) tot .lational *|iat_i eligible (/ rat 4, 1992) tot `latior.j 1 Rqi8t*t eligible ii -.-at 4 , i*>92l tot 'Jationul egut. eligible f* net 4 . 1992) tot Natron*. togis~* eligible (August 4 , ..2) Not National agtsta* eligible (Ajquat 4 , L792) No need to evaluate . 1. r bllity (August 4, 1992) 11. Houaa and garage or equip ment shad* ** Naw barn capias* tot totionel Ragiatar eligible tot National Register eligible tot totimai -agutec eligible (Nc.jNcar n l**!: tot National Ragiirn eligible (NotuUar 19 :>*l) *Uia/t OS, May 1991, Table 3-9: descriptive label from Table 3-9 in parentheses wh*n diffgn-nt. Cocoa in succeeding Ium niiti to 7A/SW0 ooirMpondinci, copies of wnrch vt rspcoducsc ui this Appendix of the Final OS for the project. D-7 HONS 009684 :<lw 'vO STATE PA*XS ^RECREATION -Of , V. i-;/>: 1 . i = :/ Qffi Lehman Comrrvssionar October 28, 1981 'X3DC Mr. Stephen Arella Environmental Impact Branch U.S. Environmental Protection Agency 26 Federal Plaza New York, N.Y. 10007 Dear Mr. Arella: Hudson River PCB Reclamation Demonstration Project Proposed Containment Facility Ft. Edward, Washington County The State Historice Preservation Officer (SHPO) has reviewed the documentation you provided on this project. Based on this review, it is the SHPO's opinion that the pro posed pipeline construction will not adversely affect the Old Champlain Canal, a property listed on the National Register. The proposed construction is limited to an area of the canal ditch that has been damaged by road construction and which contains no distinguishing features. Should you have any questions concerning this matter, please contact the project review staff at 518-474-3175. C : ...ml ,, Ann Webster Smith Deputy Commissioner for Historic Preservation D-8 e*iO00Our ty HONS 009685 1E.V TOR* STATE PARES 4 RECREATION November 19, 1981 Mr. Stephen Arella, Chief Environmental Impact Branch USEPA Region II 26 Federal Plaza New York, N.Y. 10278 Dear Mr. Arella: Hudson River PCB Reclamation Project C-36-1167 The State Historic Preservation Offlcer(SHPO) has reviewed the documentation you provided on this project. Based on this review, it Is the SHPO's opinion that the "new farmhouse" and complex referred to In your October 30, 1981 letter Is not eligible for the National Register. It Is the SHPO's understanding that additional material will be submitted regarding the prehistoric sites, the historic archaeological sites and the "old bam complex" before an SHPO opinion can be provided concerning these resources. Under separate cover, the SHPO has provided his opinion on this proposed project's impact on the Old Champlain Canal, a property listed in the National Register. Should you have any questions concerning this matter, please contact the project review staff at 518-474-3176. Historic Preservation D-9 *T4 . Oooo^'j'- '* r -pOver HONS 009686 Advisory Council On Historic Preservation 1922 K Street. NW Washington. DC 20009 January 15, 1982 Hr. Stephen Y. Arella Chief, Environmental Impact Branch Region II Environmental Protection Agency 26 Federal Plaza New York, NY 10278 Dear Hr. Arella: On December 9, 1981, the Council received your determination that construction of water intake end outfall pipelines for a PCB containment facility In Fort Edward, Washington County, New York, would not adversely affect the Old Champlain Canal. The canal is Hated in the National Register of Historic Places. We understand that it is your intention to complete evaluation of other historic properties that may be affected by construction of the containment site, and (if appropriate) request the Council*a comments concerning project effects on those properties et e later date. Therefore, the Executive Director will not object to your determination of no adverse effect for the Old Chemplain Canal If you will agrea to the following specific conditions: 1. EPA will complete the evaluation process and determine, in accordance with 36 CFR Section 800.4(a), the National Register eligibility of the two prehistoric sites, the two nineteenth century barn structures, and the "Victorian Style" house noted on Existing Site Plan-l (Attachment). 2. For those properties determined eligible for the National Register, EPA will complete compliance with 36 CFR Pert 800, Including en assessment of possible visual effects on the "Victories Style" house (if; it Is determined eligible.) If you sgree to these conditions, please sign on the concurrence line below end return this letter to us. These will then be incorporated into your determination of no adverse effect for the Old Champlain Canal. D-10 HONS 009687 2 In accordanct with Sactlon 800.8 of th Council's regulation!. a copy of your dattrmlnatlon nf nnadvtr.e attack. .1odd mu,-.uiS,tir. ml thl conditional concurrents. should ha Included in wr record of rn"H.fY with tna national STTronaental Policy Act, Section 106 of tile National Historic Pr...ryitinn Art, anA rk. Council' s regulations. ~ Thank you for your cooperation. Sinparely, Jorinjn E. Tannenbaua Chief, Eastern Division of Project Review Enclosure 1 concur: V (date) '--/->/J ? Environmental/ Protection Agency, Region II D--11 HONS 009608 ,AVQ P'.i.-;i.NEW YORK STATE PARKS & RECREATION Age"ev Suiting ' frr0.'e r>i.e A.r.ai-v `Jc* <-n- Qttn Lehman Commissioner "-icmaiion s'd a: i 'WW August 4, 1982 Ms. Anne Norton Miller, Chief Environmental Impacts Branch USEFA Region II 26 Federal Plaza New York, NY 10278 RE: Hudson River PCB Reclamation Project C-36-1167 Dear Me. Miller: The State Historic Preservation Officer (SHPO) has reviewed the documentation you provided on this project. Based on this review, it Is the SHFO's opinion that the two nineteenth-century barns (Site 7), prehistoric site 4, and the four historic archaeological sites (2, 3, 3 and 6), the two twentieth-century dumps, the segment of the Hudson Valley Railroad and the Victorlan-style house are not eligible for the National Register of Historic Places. In addition. It is the SHFO's opinion that prehistoric site 1 and the Dead Creek bank prehistoric site will be avoided and therefore, no evaluation of their National Register eligibility is needed. This, plus our letters of November 19, 1981 and October 28, 1981, constitutes the SHFO's opinion on this project. Should you have any questions concerning this matter, please contact Mr. Bruce Fullem of our staff. Sincerely SR/sl cc: L. Basa Deputy Commissioner for Historic Preservation D-12 HONS 009689 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RCOION II 29 FEDEBAL PLAZA NEW YOBK. NEW YORK 10279 11 AUG WU2 nr. lObsrt Garvey Executive Director _ Mviaory Council an Historic Preservation 1522 K. Street. N.Cf. Haahingtcn, D.C. 20005 -- ear Hr. Garvey: Dm Bivircneantal Protraction Agency (EPA) has complied with the Council's aooditiona regarding our Jalamination of no adverse effect for the [ii i m sail lapact to the Old Qiasplain Canal, a ptpeerty_listed_ca i -T3f"Ittstoricmaoaa."Ao sEIpuCitedIn the Council's January 15, 1982, letter, the EEA has ocspleted the evaluation process tat the resources enueerstad. A Stage II cultural resource survey was conducted to obtain data needed to evaluate the potential eligibility to the National Register of tec prehistoric sites and two nineteenth century bam structures. Hires additional historic archaeological sites were Identified 2nd evaluated during this survey. Hie EPA has also provided the New York State Historic Preservation Office (SHPO) with documentation on the "Victncian-style' house located in prosimity to the proponed PCS oontainoant site, in consultation with the SHPO, the EPA fooaalatad their opinion that the two bam structures, one of the prehistoric sites, the Victorian house and the three historic archaeological sites do not east the criteria for eligibility to the National Register. Hie other prehistoric site is located in the buffer sane of the ptoject area and will not be inspected by the proposed project. To address the Council's aonoem for visual effects of the imposed ccntainant site, we have unclosed a series of photognphs illustrating a model facility. Die photographs illustrate e acmplete encapsulation site at Mgreeu in Saratoga County, New York. Hie series doeueant the effects on the landscape during md after construction of an encapsulation project. If you have any questions, please call Hr. Richard Nalka at (212) 264-1858. Sincerely yours. Anna Norton Hiller, Chief hrlrre--ntel Ispscts Branch act NXS Historic Preservation Officer NIS PepsiPlant of nwirtan--nrel Conservation Attachaent D-13 HONS 009690 APPENDIX B OOWENT LETTERS RECEIVED CW^THE SUPPLflfEAt"DEIS HOMS 009691 E-l DEPARTMENT OP THE ARMY NSW YORK DISTRICT. CORPS OP SNOINURS as PCOBRAL PLAZA NSW YORK. N. Y. 10170 *FLV TO ATTCMTION OFi MNCP-E Ms. Rabin Rahn Envirorwental inpect Branch U.S. SavircnDsntAl pcotsction Agency R^ion II 26 Federal plaza - RDca 404 DM ISCk, NY 10278 14 October 1961 Daar Hi. Bohns Inclosed an ccsownta of tbs Oocps of Bginaers on the review of the *vpl> --ital Draft impact Statement for the Hudson Diver PCB art spot Bodging project. please incorporate these aoncems in the Baft oivironnantal impact Stataamnt. ' Sincerely, (`jtw ZM#icr 1 Chief, operations Division E-2 HONS 009692 REVXSi cr SUPPLEODTXL CRAFT ' ENvnmsNiw. impact stcekent ai the hgdsch rives pea project___________ a. pacutlva Simaary (S) Ho cannarits to tnis section - satisfactory * b. Modifications consents to CC1S (Chap. 2-3) 1. Response eo our request for closa coordination with stata arts private dredging aeeiona baa not basn adaquaealy addressed. Wt an not . proposing usa of material froa outaida the project ana. it should oa rstad that tba CK also ncanaandad that a PCS managenent plan ba davalopad. 0-13). DEC should actively develop a plan to snoouraga both OCT artf private individuala/antitias to achadula all opantions in this part of tha rivar eoneumntly with tha DEC. This would serve to ansun maximum usa of tha eantainaant ana and mlninize interference with monitoring afforts. This eight antail infosaing all potantial uaars of eha difficulty inharant in dealing with tba probles on thair own. Transfar of finds to DEC might rasult in substantial savings to tha applicant tftilt expanding tha amount of FCB's safaly moved. 2, Tha DBS still dcasn't clarify tha posaibla arronoua conclusion of aaauning tha daolining lavala of PCB in fish associatad with tha raiativaly 1cm flow doting tha prat fiaw yaars will oontinua. Cleaner depoeits hava covarad PCS sediments and tha fish hava baan aquilibnting with tha subsaquant lower lavala in tha rater. Tha hot spot anas still main howavar, and tha first good flood could eisily ncbilizt them by stripping tha still thin, cltan, sadimant cover thus making tham availabla to fish. 3. Ths impact Saction was impeovad by tha addition of tabia 2-1, (--91, which ahould pncaad this chaptac. Same improvement in tha layout of tha table is still needad. it is suggastsd that tha tabia ba laid out langthwise (along the U Inch atis) and utilize 2 adjoining pages so as to oaks all ooaponants and impacts visible at a glance. 2. imsponsa to ths executive aunaary hava been previously forwarded. The landiftad response presented in appendix A of the supplenental DEIS addressed sobs concerns but failed to respond to comments on the critical studies for the environmental monitoring. Specific comants to the now response are as follows: a. operational Standards (A-18) Much of our original concerns here have been satisfactorily dealt with, especially in tightening up frequency of smapling. Three concerns, however, still main: . 1. m discussion of ssapiing frequencies at the oontaiitnent site tha statement".... smaplad in acsordanca with the site permit (TSCA)*, appears at a number of places yet there is no permit available to determine r __ MONS 009693 what the criteria ate. Evaluation is therefore not pass ibis, a copy of the permit should be included or the specs incorporated 'into the doctaar.t far ready availability. 2. Thresholds for implsnenting contingency actions have been aided, as requested, though useful, many are too general, not providing enough specific data on hew and when the plans would be initiated. ' ' 3. there is ouch discussion on PCS.uptake by plants, yet no method has bean described for the disposal of the grass cuttings resulting frtn site maintenance, the primary reason for cutting the grass was to prevent its ingestion by wildlife, if such a potential hazard, it should oe disposed of safely, at least until the monitoring progran establishes its safety (if such a Conclusion results). b. BTvironnental Monitoring program (A 36 - 49) 1. Our original oaments do not appear to have been answered. Much of the pcepoeed studies lade any detail to consent cn and as such can not be properly reviewed or judged. A copy of our original contents are enclosed for reference. 3. In addition, the following should be addressed: a. The docutmnt does not state whether barge overflow will be allowed or not during clamshell dredging of the hot spots, oia: own experience indicates that allowing no barge overflow will reduce the impacts of dredging. b. The document reccneands that no action be taken at regnant areas 3 and 5. However, on p. n-1 the issue of husan use of these area is not resolved to the seme degree oe the pcs volitilization issue. The issue of human use should be more thoroughly investigated before no action is reocumended. c. Cn p. IV-55, the first paragraph ends by stating, "larvae of ' Chircnoaoua tantans accumulate DOE at the sane rate whether alive or dead". la this statemen~cocrect? E-4 HONS 009694 STATE OF NEW YORK A DEPARTMENT OF HEALTH OFFICE OF PUBLIC HEALTH TQWt* UIWOIWO 0*vie UIIMO. M.O. (MNMWNT 9WSWM C. MAUOHiC. .3. TXf OCVfRNO* WCUJOH A. OCKKFCULM STATl AlfAMY. H.Y, *tXXT OIV1SIOM OF CKVIKOMMCXTAC HtAWTM LtO t. MKTUIH9. 9M.S. October 15, 1981 Chief, Environmental Impacts Branch US ERA - Region II 26 Federal Plaza - Room 400 New York, New York 10278 RE: EIS Hudson River PCS Reclamation Demonstration Project - Supplemental Oraft Oear Sir or Madam: We submitted comments on the Oraft EIS on July 6, 1981. The above Supplementary Oraft answers some of the questions we raised In our letter. The Quality Assurance Plan sent to us by the New York State Department of Environmental Conservation provides addi tional detail on the monitoring programs, which we consider of central Importance to the project from the standpoint of protection of public health. Our only serious remaining questions concern the details of the air monitoring at and around the containment site-,- Our Interpretation of various statements In the original draft, the supplemental draft, and the quality assurance plan Is the following: one air sampler will be set up on the site adjacent to the basins and In such a location that It measures the highest concentration at the containment site. Samples from this monitor will be collected dally. Other monitors will be stationed at nearby sensitive receptors, and there wfll be mobile samplers that can be moved as necessary to verify dispersion predictions. Sampling will be conducted weekly at sensitive receptors; there will be a total of 100 samples per dredging season from the mo bile and sensitive receptor monitors, providing an average of 1 such sample per day of dredging. We are concerned that this may not provide adequate assurance that ambient levels are within the guideline value established for the protection of public health. More explicit fnformotion should be provided on the sampling that will be carried out. The so-called sensitive receptors should be specifically identified, the criteria for sampling at any particular location should be given, and the general strategy for measuring downwind concentrations on any particular day, taking Into account variations In wind direction, should be described. HONS 009695 E-5 Page Z October 15, 1981 On page A-13 of the Supplementary Oraft the maximum ambient air concentration of 1 ug/m3 established by NYSOOH is referred to as a "safety guideline set by NYSDOH for residential exposure." This is an improper interpretation of the Intent of the Health Department. This Is not a safety guideline for residential exposure but rather a maximum value for the limited duration of the proposed project; it would not be acceptable for long term or continuing exposure of the public. On page A-20 there is a discussion of air sampling at the dredge to determine whether workmen, and possibly residents along the shore, may be exposed to PCS concentration in excess of the value determined to be acceptable for public health. According to the information provided.air sampling will only be performed for the initial 10 days of dredging. This should be modified to Include monitoring on the first days when elevated temperature and low wind speed conditions are exper ienced, leading to a greater evaporation rate and a corresponding in creased likelihood of high PC8 concentration. Limiting such sampling to the initial 10 days, particularly if they are in the Spring at the beginning of the dredging season, probably will not corespond to the maximum likelihood for PCS exposure. Additional sampling should be conducted beyond the proposed total of 20 samples at the dredge and the unloading site, to Insure that samples are taken at both sites under conditions of maximum volatilization. The EIS should contain references for the various calculations - of ambient air concentrations projected for the project. On page A-4Q of the Supplemental Oraft reference is made to a probability table, two studies of gas transfer, and various calculations and reports by Malcolm Pimie Inc., but references are not provided to any of these data sources. On page A-58 there is a list of four conclusions from experience with dredging in the Hudson River. The fourth conclusions is, "The worst cate condition is likely at a low flow." Two interpretations are possible; the rate of loss of dredged material is greatest at low flow, or the con centration of PC8s In the water immediately down stream of'the dredge is greatest at low flow. The first interpretation would not seem to be truebut the second would.However, there is also reason to consider that the great est rate of loss of dredged material is a "worst condition" rather than an increased concentration immediately down river from the dredge. In any event the meaning of the statement should be clarified. On page 3*11 of the Supplemental Draft, in response to comment number 11-14, it states that if dredging causes unexpectedly high contaminant con centrations at downriver drihking water intakes, contingency plans for pro tection of drinking water will be implemented for high levels of metals as well as for PCBs. On page A-22 the sampling procedures are provided. The action level for PCS contamination is mentioned in the EIS, but no value is given for any metal. We assume that the maximum contaminant levels in the State Sanitary Code will be used to determine if metal concentrations in the Intake water are so high that contingency steps should be taken. MOMS 009696 E-6 rue J _ October 1:, 1981 The Supplemental Draft changes the statement, on page 3-17 of the EIS to reflect the new lower EPA water quality criteria for PC3s in water. The statement as revised, however, appears to indicate that the USGS monitoring data at Poughkeepsie and Waterford indicate that PCS levels are Below 0.C7S ng/1. A reference should be provided. In any event, if monitoring data is referred to, the year of sample collection should be provided as well. The water quality criterion of 0.079 ng/1 for PCBs should not be used to judge drinking water quality. Water quality criteria consider the inges tion of contaminated water and contaminated aquatic organisms taken from the water body. Orinking water guidelines are for the ingestion of finished water. ' The Supplemental Draft does not answer any of the questions we raised regarding the estimates of PCS flux to the atmosphere. We still question some of the steps in this analysis. Therefore, we consider provisions for air monitoring and timely implementation of contingency plans to be essential. The EIS should provide more detail on air monitoring at and adjacent to the containment site. NKX:yaw 01 rector Bureau of Toxic Substances Management MONS 00969 7 E-7 GTY Of NSW YORK D----E- PMAU--H-R-t-Q-T-PMM----ER--A-N--O--T-t-H--^OO. F.N..(W.E. NTCVI.R.N..O.r. N_1_0_0M_0_7ENTAL PROTECTION (717) nUNOS X. McAXOU. C*MnttBtnr 8 October ]98) Sr. Steven Arella, Chief Qtvirormental Impacts Branch . U.S. Ehvironnental Protection Agency Region n 26 Federal Plaza, root 400 HSw YOdc, N. Y. 10278 Re: Hudson River PC3 Reclamation Dsmonsmation Project Supplemental DEIS, August 1981 Dear Mr. Arella: - we have reviewed the Supplemental DEIS for the Hudson River PCS reclamation project. Since the docunsnt does not address potential itsacts to New York City, we consider the 0E3S to be inadequate. Our general concern is that the DEES does not daesnstrats what the downstream transport of PCSs would be during high flow conditions. Despite the dccment's claim that dredging will not have a detrircental effect cn downstream water supplies, it is apparent that resuspension of PCS-Laden sediment could increase concentrations to an vBacesptable level. As is notsd in the DEIS, data for water year Octabtr '76 Septsnfear '77 revaal maxinun PCS ooncar.trations for Schuyierviile, Stillwater and Waterford of 2.2, 2.4 and 1.4 uc/1 respectively, all well above the 1.0 uq/1 nandmua level established by NY3DCK. it can be seen from- these figures that it ia possible for PCBs to be trsnspartad as a pollutant slug, most probably under high flow conditions. Specifically, this could irpact the possible resetiva- . tion of tha Chelsea Pnp Station should drought conditions necessitate using Hudson River water far Nsw York City water supply. It is planned in tha DEIS that dredging will stop if the river flow reaches 20,000 cfs. However, high flow conditions range upward frca 12,000 cfs and a 100-year stoma has a flow of 30,000 cfs. Given that tha nomad. Hew at the dredging site is about 5,000 cfs, we believe that this 20,000 cfs threshold is too high, unless it can be documented that there will be no long-range transport of PC3s. Unfortunately, this type of analysis has noe been dene. The sampling progrea as designed would not give New Ycrk City sufficient time to switch off the pimping station before resuspended PCSs are introduced into the systea. In sun, if New York City needs to activate the Chelsea >mp Station during the dredging operation, we cannot ba assured that PCSs will not anear our drinking water simply. E-8 MQNS 009698 usax 8 October 1981 page - 2 - The effect cf upstream dredging on PCS transport a, and acsrailaticr. in. New York Harbor is not adegaataly addressed. As notad in the DEIS, should PCS deposition incraasa in tha Harbor, levels above i ran could preclude ccaan disposal of maintenance dredge spoils iron the Harbor. Ciara is no discussion or napping in tha DEIS of currant site-specific Harbor levels of PCS, nor quantification of how the levels might be altered under high flow conditions. Additionally, there are no data on depositional rates in Mew York Harbor. Giver, that Haw York is considering scene substantial dredging operations in connection with the coal facility ir. Statan Island, this'project could have a significant eoancmic impact. ' Our recaanandatlons are as follows: - the DEIS should analyze the insects of long-range transport of PCSa under high flow conditions and determine what cutoff (threshold) points are needed at the dredge sites to insure that PCBi will not enter drinking water supply. Frequency of highflow conditions and quantities of PCB trax -sported at various flax rates within the "high flow" range must be documented. - Bm DEIS should dssign a sanoling program so that dally samples are taken upstream from Chelsea with sufficient time for analysis to be completed before PCSa could reach the intake. - Cm DEIS should document current PCS levels in Mew York Harbor sediment and quantitatively determine rates of transport to tha harbor under varied flow conditions. The docment can then more accurately address the project's inpacts on our ability to dispose of dredge spoils in the ocean. -- . thank you for this opportunity to ccnmant on the Sucplenental and Draft Bwirormantal Inpact Statements. If we can be of any assistance to you, or if you wish clarification of any points raised in this letter, please do not nasitata to contact ma. Hobart L. aru^gfc Assistant Ccmoissioner Department of Environmental Protection E-9 HONS 009699 DEPARTMENT 0? HEALTH 4 HUMAN SERVICES `-W'C 3rvic Ctrtttn `or 0*mm Control Att*nt. Gtcf^ ZQZZZ (c04) 162-6649 Occobar 7, 1931 Chiaf Envlronaaneal Inpacts Branch O.S. Envlronaaneal Protaction Agancy Region II 16 Ftderal Plaza, Root 400 Mav York, Nav York 10278 Daar Sir: Thank you (or sanding us a copy of Che Supplmantal Orafc Envlronaaneal lapset Scaeaaanc (Eli) for cha Hudson Rivtr PCS Reclamation Demonstration project. Ua art raspondlng on bahalf of eha Public Haaleh .".erviee. Ua undarscand chsc cha recoaanded action Is Co undarcaka eha origin illy proposed $40,000,000 full-acala preface with eha required aodificaeion*. Sines our June 30, 1981, comments on eha former Draft EIS vara noe spaclflcally addrasssd In eha EIS, va trust thac chasa coaaeaes will ba addrassad la cha Final EIS. Ua hava no addlclonal comments to offar ae this ciaa. . Ua look forvard eo racalvlng a copy of cha Final EIS as soon as It bacoaas available. Slnearaly yours Frank S. Lisalla, Ph.O. Chiaf, Envlrensaneal Affairs Croup Environmental Haaleh Sarvlcas Division Cancar for Envlronaaneal Haaleh E-10 HONS 009700 It i.\ DEPARTMENT of ports AND TERMINALS Vt-Tj Uatiirv Maritunt Bui]dmj. N York. \.V. IOOW -? ,'P Ttitphcnc: Z\Z-Z*S- October 13, 1S8L Robin Rohn, Project Manager Hudson River PCs Reclamation Projact Environmental Protection Agency 26 Federal Plaza New York, New York - Dear Ms. Rohn: I have reviewed che supplemental draft of the environmental Impact statement prepared by your agency. I chink it would be helpful if you would provide an exact breakdown of how che 26 7 million dollars will be allocated among Che various components of che project. Specifically, how much money will be expended for: 1) actual dredging of the "hot* spots" 2) mitigation measures outlined in E.I.S. 3) owntcoring devices for water quality 4) monitoring devices for air qualicy ' 5) water qualicy protection devices for communities which rely on the Hudson River as a source of drinking water 6) construction of che containment sice 7) monitoring of Che containment faci lity S) future research Thank you very much for all your time, attention and patience. I look forward to seeing you at che next C.A.C. meeting. Sincerely, -11 HONS 009701 fScact lini.a.-slcy c f:.v York Stony Brcc. York I; 73U DATS June 29, 1981 70 ?P?/EC - J. Wood \ 0 3/"?F2o Stanfojd^^ ^rk-~n ROM SUBJ CSIS 8105.23 -- Hudson River PCS Reclamation Demonstration Project Northeast Office, connents are directed primarily to those parts of the DEIS that pertain to the Hudson-Rarltan Estuary. Co.tre.nts are: 1. The no-action alternative has received woefully inadequate attention. 2. Because of the Inadequate attention to the no-action alternative, a definite bias toward an action alternative ap?ers_to have resulted. 3. The "Purpose of and Need for the Project' (paces 1-5 to 1-10) do not truly define the need for the proposed action: a. Printing water - 1. There -Is no indication that PC8 concentrations at gauolne stations (not at those points where drinking water is drawn) are increasing with time. In fact, the data.in Apoendlx A suggest a decrease In time. ' 2. The PCS concentrations at gauging stations are indicated at no higher than 0.687 ppb (sometime between 1975 and 1979), considerably below the maximum level of 1.0 ppb presently reconmended by the New York State Department of Health. 3. As is Indicated In the DEIS, "PC8s ear be removed from river water, leaving It suitable for drinking." . From the DEIS, It appears that there is r: drinking water problem, end even If there were, it could be taken care of. b. Food 1. In the DEIS, It Is stated that 'Comprehensive human food monitoring data on PCS levels are not available for the Hudson River are*.' It seems inappropriate to make large- scale decisions without such data. E-12 HONS 009702 pp/C - J. Wood Pig* Two June 29, 1981 2. Also In Appendix A, there Is a statement that "Recent trend analyses on levels of PC8s in uoper Hudson River fish indicate that a 5 ppm level may be reached by mid-1980 without dredging and possibly sooner if contaminated sediments are removed [Emphasis added.). 3. There is a statement that "the possible local exoosur* to PQs resulting from the opening of the fishery in the uoper Hudson ! River must be considered* (Emphasis added.1. c. Routine Maintenance Dredaino 1. It would seem that jhf such dredging were necessary around hot spots, then special precautions (such as those proposed in the DEIS) could be used for Just those particular cases. 2. -- There is no convincing agreement presented that the project will lower the level of PC8 contamination in sediments of the lower Hudson River. Therefore, there is no indication as to how dredging there could be imoacted under the no-action alterna tive. . .. d. Hudson River Fishery 1. There is an indication of a loss of value of the Hudson River fishery. This does not include assessment of how much of this value is really expended elsewhere in the general area, fisher men aren't going to quit fishing; they will just go elsewhere. 4. In Chaoter 2, "The No-Action Alternative" settiojLdoes not indicate how much of the routine channel maintenance dredging would be at the hot spots -- if any. Also, there is confusion as regards the volatilization matter in that the amount volatilized before dredging is not compared to that which would exist if hot-spot dredging were to occur. The price question to address is really the concentrations of PCBs in sediments and thair changes ovar time with or without some action. 5. Under "The No-Action Alternative" presentation in Chapter 2, page 2-3, there is no reason given for the assumption that 100 percent of the PCS load at Troy enters New York Harbor ..." The fact that PCBs settle in the Troy turning basin negates this. Also, what evidence exists for increasing PC8 concantration in the turning basin? If that were trua, why not dredge there, as would otherwise be necessary, and properly dispose of that material which would have to be dredged anyway? E-13 HONS 009 703 ??/EC - .0. Wood Page Three June 29, 1981 6. It Is evident that short duration high- flows in the past have transported PC8-contaninated sediments. It is not evident that will hold true for the hot spots. If it did, why are there still hot spots? Obviously, shortduration high flows had relatively little impact previously on hot spot areas. 7. Downstream deposition is dealt with in a very hyoothetical manner, with little evidence for the suppositions. Also, if the physical composition of the transported sediment doesn't change, then the PC8 concentration won't change either. 8. throughout the DEIS there is conjecture with little, if any, supporting factual data and information. This is particularly evident as regards PCDFs (page 2-5). Is there any indication of a problem? 9. It is stated that the "Mo-Action Alternative (Assuming That Routine Channel Maintenance Dredging Will Be H.ilted)" will heve greater negative impacts than the "No-Action Alternative (Assuming That Routine Channel Maintenance Will-Continue)". This is not substantiated to any sufficient degree. All in all, there' is insufficient rationale for considering further anything but the no-action alternatives. Should you desire any additional comments, or clarification/amplification of those provided, please advise. cc: L.W. 8utlcr J.H. Kravltz P.IC. Park J.R. Schubel R.L. Swanson NEO Staff E-14 MOMS 009704 Natural Resources Defense Council, Inc. MAta or ravmn MHarDtHUA (Mm 133 XAST 43NO STRUT NSW YOXXf N.Y. 10168 tu 949-0049 October l4f 1981 CfU* 1755m1 iTns6tr0r0. s.w. wajmikotox. 8.0. *ooo4 to* Steven Aralla Chief, Environmental Impact Branch a.S. Environmental Protaction Agency Ragion II, 26 Federal Plaza Room 400 New York, New York 10278 WaMnOfbr >) iuui rrmtrr 94.eSsan rtANCisco. calif. 4>J 411-SjS. Daar Nr. Aralla: * Tha Natural Resources Defense Council (NROC) appraciataa this opportunity to comment on tha Supplemental Draft Environmental Impact Statemtnt (SDEIS) on the Hudson River PC3 Reclamation Demonstration Project. In our comments on the DEIS we identified eight major Issues that should be resolved before EPA approves tha project. (See Appendix A to these comments.) The DSEIS begins to address some of these issues. However, it has a number of shortcomings- which we identify in the following comments. Me look forward to working with you on the continuing review of tha PCB Reclamation Demonstration Project. jHNMMWMr Sincerely yours, y&JtLOL 'v`lutTw tymic* Silverskain Karim Ahead, Ph.O. ior Staff Scientist S CA&y^ ah Chasls Senior Staff Attorney JS/XA/SC: skb cc: James S. DeZolt HONS 009705 John Sanders S'cm Office: 1Cujieni ; out Mm naticx. ma. 01760 617 833-2656 Public Landc Institute 1657 mx.Nm.VA.NU mur oesvm. co. 3o*o) 303 831-7101 E-15 Natural Resources Defense Council, Inc. 111 tA.1T 42NO STXIZT NSW YORK, N.Y. I0l68 vf tiuitiii AMm vr. Dwtn* Imm MjmMU Hn CkttMM rbfCWmw Brcw(iU,iVNiMii nwoiNn DuDwUMmm t) 3 949-0049 . 17S5 t JTXttT. 5.W. scirx 9o WAJHIXCTO.V. 9.C joooS tot }:3-l:io OJta 33 XtAt^Y ITZtST A.i rtAMCtsco. CAur. 9410 4*3 48*-3 totanatuu wmin T. t rrmrlTti - ^------- J ilK.Cntf JinLDn BfcAOMj. &vor. CHw-- tr.lteNfc.Jv. C Jwltef MtasLUnm MaLiiMt eCMlft.*** jrnm%0mm M.LI Lmm E ONfcwfc TtMM.WTlOTV COMMENTS OF THE NATURAL RESOURCES DEFENSE COUNCIL ON THE SUPPLEMENTAL DRAFT ENVIRONMENTAL IMPACT STATEMENT I ON THE HUDSON RIVER PCB -- RECLAMATION DEMONSTRATION PROJECT October X4f 1981 Janies Silverstein Kasim Ahmed Sacah Chasis MONS 009706 .Vn Enjlend Offlee: 17 nut owvt nattcs, sca. 01760 617 Sjj-rfjS Public Lunds Institute: 1(57 mzrrFtNMm.vA.tiA ocm*. co. Soso) joj 6)1-7101 tm% IUcmM Ptpw t-16 These comments are ordered to track the tight major issu a we identified in our previous comments. 1. SOPBCSS AND DISTRIBUTION Of PC3S The major contributors of PC3s to the environment may be hot spots* cold spots* remnant deposits or unknown sources. The.,project does not allow for the importance of any source except hot spots. It is essential that the contribution of the other sources be carefully evaluated before the dredging begins. - Hot Spots i As we said previously, the concept of "hot spot' dredging is a good one. However, hot spot criteria should consider not only concentration but also scour, desorption and total mass. It is not clear that this redefinition has been considered in the resampling and monitoring program. Cold Soots Detailed information must be generated on the size, mass, location, depth of contamination, scour rates and desorption rates of cold spot areas as well as hot spots. In this way dredging can be targeted to those areas contributing the most PCBs to the environment. Once again, the program does not give adeguate consideration to cold spots. According to the description of the Coring and Fathometry Study that will be conducted by NYSOEC and E-17 HONS 009707 Malcolm Pirnie, Inc. (MPI), "detailed location naps of both hot and cold areas will ba prepared." However, coring will sake place "in and near hot spot areas." Cold spot areas will not receive the sampling that is required to evaluate their importance. Remnant Deposits In addition to cold spots, the NYSDEC response ignores that importance of remnant deposits. After an evaluation of the costs of remedial action the NYSDEC recommends that no action be taken "(s)ince evidence exists indicating that remnant areas 1 and S do not pose a human health risk and because of their isolation, stability and natural inaccessibility." These assumptions are not necessarily ture. According to Italo Carcich of NYSDEC in a May, 1931 letter to NRDC, "[tlhe most recent data for the 1930 water year indicate that the remnant deposits are a significant source of PC3." In addition the DEIS estimates that 130 ug/yr of PC3s volatilize from the deposits (p. 2-23) and that estimates of total loss vary from 200 to 1300 ug/yr (p. 2-22). The DEIS states further that *[t]he amount of ?C3s released from the remnant deposits to the Hudson, however, has not been adequately determined* (p. 4-24). This evidence refutes the conclusion that the remnant deposits ers stable. If studies have been conducted since the DEIS was published, the PEIS should cite end discuss any new evidence that has been uncovered. E-13 HONS 009708 Furthermore, the DEIS does not suppor: the conclusion Chat the remnant deposits are isolated and inaccessible. According to the DEIS, "[tlhere is evidence that children occasionally play on some of the deposits and that motorcycles are driven over them. Animals also have dree access to the sites" (p. 2-24). In addition, "[tlhe remnant deposits,especially those on the east side of the river, are in fairly close proximity to residential areas* (p. 4-24). It is essential that the remnant deposits be carefully monitored to determine their volatilization and PCB contributio to the river. The FEIS should contain a clear description of the relative contribution^ of all the remnant deposits and the studies that are' being done to make these determinations. This will allow for a clear evaluation of what actions are necessary with regard to remnant deposits. Onknown Sources . According to the OSEIS (Response VI-1), "As part of the pre-dredging baseline monitoring program designed by MTSCEC for the dredging project, the presently unknown source of KBs in the Upper Hudson River will be identified, and remedial action, such as removal, will be undertaken." However, the monitoring program described in Appendix A of the DS1IS does not include a study to Identify unknown sources of KBs. 2. KB TRANSPORT He are pleased to see that a study will be done to examine the rates of KB desorption and erosion from bottom E-19 HONS 009709 sediments of the rive. This may help to clear up the questions of the "low flow anomaly" and to improve the predictions of the Hydroscience model* . However, the study_ is not being used to help locate the primary source of downstream PC3s. If the model shows that at low flow desorption is the principal release mechanism and at high flow erosion releases the most PC3s, then the relative PCB release at low and high flows must be determined. As we suggested in our July 7th comments: If the PCB load In lbs./day were multiplied by the number of days in the year that such flows occurred, an estimate of the amount of PC3s transported under low or high flows could be made.( ' This would be important in deciding whether to dredge those areas most lifcely to be scoured or those that desorb most readily. For example, if yearly low flow contribution is higher, then areas of greatest desoortion should be dredged. It must also be considered that contaminated sediments that are scoured may resettle faster and cause less harm than PC2s that are desorbed into the water column. Furthermore, the study will examine the effects of sediment quality on the relationship between desorption rates and fiow velocity. This information may be useful in determining which sediments desorb PC3s most readily. However, the study will only examine "hot spot' sediments from the area proposed to be dredged. The cold spot sediments will not be examined. However, cold spot sediments have different settling qualities and may be larger in size or lower in E-20 HONS 009710 3 organic material- than hot spot sediments. Cold spot sediments nay also havt significantly diffartnt desorption characteristics. Therefore cold spot sediments should also be examined. 3. SAMPLING AND MONITORING : According to the DSEIS (Response 11-2): < As part of the pre-dredging monitoring program. NYSDEC will sample sediments in the Upper Hudson River to define hot spots, as well as areas with less than SO ug/g (ppm) PCBs, in terms of location, extent, PCS concentration, depth of contamination and FC3 mass...NYSOEC will also assess how susceptible the contaminated areas are to scouring under normal and flood conditions. This pre-dredging samp.' ing is described in Appendix A. However, the sampling program described in Appendix A does not include projects to fully resample hot and cold spots as described in Response II-2. The resampling study must be described in more detail. In addition, there should be an opportunity for the public to review the results of these studies and to provide input to decisions on where to dredge. In order to facilitate this public review, a document should be published that discusses the results of pre-dredging studies and proposes modifications to the dredging plan based on ths information that is uncovered. The following are our detailed concerns with the Operational Standards and Procedures, Mitigating Measures, Contingency Plans and Environmental Monitoring Programs that are described in Appendix A of the DEIS. E-21 HONS 009711 (a) Dredging In River Containment and Stabilization - Art til tht residents who will be contacted before dredging commences now indorsed about the project? (A-13) ' -- Air sampling at the unloading site will be performed . . only if sampling at the dredge Indicates concentrations of 1 pg/m^ or higher. It is assumed that PC3 volatilization at the unloading sits is comparable to that at the dredge site. However, the unloading site is close to the encapsulation site which will have *an overwhelming influence" on the local air quality (A--21)- in addition, the process of slurry formation may increase vclatilization. Therefore, it cannot be assumed that values at the unloading site will be below recommended standards if they meet these standards at the dredge. Sampling should be done at the unloading site as well as at the dredge. -- The water quality considerations only cover watat supply and do not address effects on biota. In addition, there is no provision to curtail or alter the dredging project if unacceptable levels of PCBs are discovered. -- In order to minimize resuspension of sediments and down river transport, dredging will be limited to "periods of relatively stable flow" (A-- 23). Dredging will not be done under flood flow conditions at a E-22 HONS 009712 threshold of 20,000 cfs. now was this threshold determined? According to the DEIS (p. 2-9) average , flow at Fort Edward is 4,000 cfs. A flood threshold of 20,000 cfs seems unreasonably high and far from "Stahls flow" conditions. (b) Disposal -- Surface water quality considerations estimate maximum monthly average PCB concentration of 20 yg/1. This will result in an average daily discharge of 2 lbs/day and a 20 percent Increase over background' levels in the water column. These values are Inordinately high, especially when it is considered chat the settlement required General .Electric to reduce their average daily discharge to .0022 Ibs/per day. No contingency plan exists to decrease the concentration or halt this effluent discharge if adverse effects are discovered. (c) Long Term Storage -- The discussion of leachate discharge considers both short and long term discharges. These figures should be comperable to those for water quality effaete of disposal; however, they differ significantly In addition, thay art not comparable to figures in the DEIS. The following table identifies these discrepancies. -23 HONS 009713 -8- Water Discharge Million Gallons Average PCS Concentrations Mass of PCS Discharaed Leachate Discharge (DSEIS A-29) -Disposal Water Quality (DSEIS A-26) 5S -- 6.3 ug/1 3 lbs. over 2 years 10-20 ug/1 2 lbs/dav (DEIS 2-42) 91 -- -- It is essential that this be clarified. The effluent discharge from the containment site is considered to be the greatest PCS loss to the river from the Reclamation Demonstration Project. Although more PCSs will be removed from the river than returned as discharge/ the effects of this direct discharge into the water column_must be balanced against those of leaving the contaminated sediments in place. The PEIS should include a copy of the site discharge permit and the TSCA approval and describe any monitoring that is required by these permits. The DSEIS states that: The potential for gas generation in the containment cells is minimal because of the low overall level of organic material present in the contained material. ' However/ there is no estimation of what the overall level of organic material in the containment site E-24 HONS 009714 It is essential that dragging losses be carefully evaluated before dredging begins to avoid adverse biota effects and to accurately assess the quantity cf ?C3s that will be removed from the river. If it is discovered after . dredging starts that losses actually exceed previous estimates,-- then the project may have to be halted and funds may not be available to mahe the necessary changes. 5. TREATMENT Or DREDGE SPOIL Fortunately, the DSEIS provides a clearer description of the containment site. Construction and operation of the containment site requires a complex array of federal and state permits and certifications. It is essential that the FCXS describe these procedures along with their respective timetables. In this way the public will be informed of the various controls on the design and operation of the containment facili tv. Although long-term monitoring will not be funded by the ERA grant, it is essential that the stata be required to conduct these studies as a condition of the S?A grant. The FEIS should contain a description of the state's long-term monitoring plans. . DREDGING WETLANCS It is still unclear where wetlands will be dredged in the reduced scale or full scale projects and whether wetland values may preclude dredging cf some areas. According to the E-25 HONS 00971$ Wetlands Mapping project description, "a snail portion of some oi the wetlands adjacent to deep water he: spots and subject to scour will be dredged." The FSIS should contain a detailed description of these hot spots and the wetlands that will be dredged. In addition, we identified a discrepancy about which hoc spots overlap with wetlands. We would appreciate a detailed response to the concerns contained in our comments on the DEIS and our March 11 letter. These are included in Appendix S to these comments. 7. COMPENSATION FUND In our previous comments, we identified the need for a compensation fund for damages caused by the dredging project and we proposed seven principles to guide the consideration of such a fund. The DEIS contains no response to our suggestions and the state has proposed no such fund. The Section of Appendix A on Liability and Financial Assurances only states that the State is a self insurer and has adequate funds to cover claims. This is a far cry from a special fund directed at compensating damages resulting from the Reclamation Project. It is essential that the FEIS consider as a mitigating measure the creation of such a compensation fund. E-26 HONS 009716 APPENDIX A The Natural Resources Defense Council (NRDC) offers ' these cerements in response to ERA'S Draft Environmental Impact Statement (DEIS) on the Hudson River ?C3 Reclamation Demonstration Project. The DEIS recommends dredging 40 spots in the Hudson River contaminated with ?C3s. Since it projects insufficient funds for this dredging operation, the DEIS also endorses a project, reduced in scope, that would remove fewer hot spots. ---- Having reviewed the DEIS, we believe that there are still several central Issues that have not been addressed. He identify these issues below, and point out why we believe that they must be resolved before EPA approves the project. 1. The major source of downstream ?C3s has not yet been adequately identified. The proposed Reclamation Plan involves dredging only the "hot spots" in the Upper Hudson. It assumes that areas of highest PC3 concentration contribute most to the downstream load and concludes that they should be dredged first. let many hot spot areas are stable sediments and may be scoured under only the severest flood conditions. Some sediments containing relatively lower concentrations ef PCBs appear to scour at a higher rate and could be contributm significantly to the overall ?C3 downriver flow. 2. The primary method of PCB transport in the water column, whether dissolved or adsorbed to particulates, has not been clarified. To properly assess remedial measures we E-E7 HONS 009717 - 1- need more information about the mod* of transport, If ?C3s, for exainple, are carried downstream on sediments, areas of high scour should be dredged; if thsv ars desorbed Iron sediments and carried downstream in the water phase, the areas of high desportion should be attended to. ._ 3. The possibility that the total contribution of ?CSs fr.OB low flows may exceed that from high flows has not been fully investigated. Sincs-the source of PCBs under these two conditions may differ, the appropriate remedial measures (such as where to dredge) may differ. 4. A condition of project approval should be the requirement for a thorough resampling and monitoring program. Resampling to accurately determine the locations of all PC3 sediments is essential in order to analyze the most effective dredge sites. In addition, ?C3 sediments may have shifted since the time the original survey was done. A thorough monitoring program should also be conducted to ensure environmentally sound decisions regarding the project. This program should include monitoring of: (a) losses to the water column and the air before, during, and after dredging; (b) containment site losses to river, air, and groundwater; (c) short- and long-term effects of the dredging project op. water quality, air quality, fish and agriculture. 5. The amount of PCBs missed or resuspended during dredging has not been adequately analyzed. The estimates presently given vary considerable (24 to 134). Furthermore, the assumptions made in arriving at these estimates may not E-28 HONS 009718 be applicable to the Hudson River. The amount of ?C3s lost during -dodging is an important factor to be considered in analyzing both the overall benefits of the project and the relative benefits of the different dredging techniques. 6. The method by which the dredged material will be -- treated is not discussed in sufficient detail in the sis. Thus, the effectiveness of this method in minimizing PCS losses is unclear. Furthermore, the adequacy of the containment facility in preventing PC3 losses is not clearly demonstrated. 7. What effect will hot spot dredging have on wetlands? The possibility that wetland values :tay preclude dredging of some hot spots should be thoroughly investigated, particularly in connection with the full-scale project. 8. The 0$IS fails to consider as a mitigating measure the creation of a special fund to compensate the victims of injury caused by the Reclamation Project. E-29 HONS 009719 APPENDIX 3 DREDGING WETLANDS Under the full-scale project,.it appears tiat 14 biologically active wetlands would be dredged. We have reservations about the wisdom of such an endeavor; we detailed these reservations in our latter of March 11, 1981. Under the reduced scale project, there would still be a certain amount of conflict with wetlands. The DEIS at 3-20 identifies hot spots 8 and 13 as being situated in wetland areas. In addition, it is unclear whether hot spots 13 and 19 and 20 might not overlap with wetlands. Regarding hot spots 19 and 20, for example, the DEIS at page 3-20 states that there are "no significant wetlands." This apparently means that there are no wetlands present, as the DEIS refers to ocher hots spots as having "no wetlands." We still have questions about the utility of dredging the wetland hot spots that would be dredged under the reduced scale project. If the wetlands in question serve as stable traps for PCBs and also serve other functions, such as flood control buffers, might there not be greater overal utility in not dredging them? This inquiry is inadequately developed in the DEIS. E-30 MONS 009720 overlap cr hct spots and wetlands In a DEC memorandum of Septambec 13, 1978, Alan L. itoechiain reported on wetlands south of Griffin Island. We compared the wetlands with the locations of hot scots (as shown in Malcolm Pirnis, 1973c). Tha following quotes from -- tha Roechlein memorandum ara followed by our assessment of wetlands/hot spot conflicts. (1) A long slough on_the west side of Griffin Island is an xcsllanr wetland. I don't know if it represents a hct spot but I would object to its demise. The area is over IS acres. This area includes part of hot spots 13 and possibly 15. The mean PCS concentrations are 89 and 103 ppm, respectively. (2) Small wetlands occur .north of Thompson Island...The areas, combined, are less than 5 acres in extent but represent valuable wildlife habitat. This region includes hot spots 18 and possibly 20. Their mean PCB contamination is 94 and 249 ppm. (3) "Gal us ha Island offers waterfowl brood and migrant habitat. Recreational hunting is permitted throughout this area...It would be undesirable to disturb the Galusha Island Wetlands." Tha Galusha Island wetlands are in direct conflict with hot spot number 25. The mean concentration at this area is IOC ppm. (4) "Wetlands located between Thompson Island and the Saratoga shore... I do not rate... very highly but [are! integrated with Galusha Island." Although these wetlands are not critical habitat, their destruction, it appears, may iaad to erosion or disturbanct of the Galuaha Island area. These wetlands (hot spot number 22 ere leas contaminated than Galusha Island with a mean PCB concentration of 75 ppm. E-31 HONS 009721 -3 (3) A small tributary [Tuttle Brook?] enters the Budson Rivar on the vast side, above lock 6. Snail oxbows create a deciduous wetland of seasonally flooded woods used by waterfowl. Although two acres in size* it would be undesirable to'cisturb this area. This area, in conflict with hot spot 26, has a mean ?C3 concentration of 47 ppm. (6) ' "Located south of Lock 6... the area serves muskrat, raccoon, waterfol broods and migrants. It would be undesirable to remove the wetlands. If only the floating and submergent sections are dredged, leaving the emergent sections, the area will continue to be useful for muskrat but drastically reduce waterfowl usage." This area -- overlapped by hot spot 28 -- appears to be extremely biologically diverse and active. The mean PC3 concentration of hot spot 28 is 109 ppm. (7) "Located below the New York Route 4 overpass and Thompson Road, this wetland is between 10 and 12 acres and is very valuable. It provides nesting, brood rearing and migrant waterfowl habitat. I recommend this area remain untouched." This area is entirely contained in hot spot 33. The mean concentration of this area is 103 ppm. Two other areas listed in the memorandum could not be located on the map. E-32 HONS 009722 Sdvard W. Coffin SI Ljtwlw Road. PoufhkMptlt. Nw YHc 12603 Bobla Bohn USZPA Beglon IX 26 Federal Flaza, 3a 400 Saw Tort, .T. 10278 10/9/31 Dear Bobla: Inclosed ara ax consents on recent laforaatlon aant to aa Is soasaetloa with tha Budsoa River ?C3 pro ject. I bopa they arrive In approprlata tlaa. Slnoa this la tha last coaaent period before tba final, docuaent appears, I would like to express ay appreciation for tba opportunity to participate In tba I?A- CAC process. tba opportnnlty and lasoas base bean vary eye opening and enlightening to as. Tbay have aada aa appreciate why aoaa eaa get ao enotloaally Involved In thaaa kinds of envlronaental issues. I have aada every atteapt to avoid that approach In this situation, thus %-j consents, Intended to be as objective as possible, nay be unintention ally controversial to those with a different approach or agenda to this project. I will, of course, send a copy to J.De Zolt and to Sr. Sanders and to Mr. Kulvaney. Depending on the date convened and tlae I would hope to attend what I believe to be the last CAC nesting. At any rate. If there Is not one, I hope to receive a copy of tha final BIS. E-33 MOMS 009723 TO23A Region II Snvlranmental Impacts Branch 26 Rsdsral Plaza, Room 400 lur Tort, HT 10287 51 Laksvlsv Scad Joughksspslo.HT . 1260J Subject: Comments oa Hudson Rlvtr PC3 Project. Reference: SPA-SIS, Supplemental Draft, Aug. 1931 Klsc. previous references. Aa Increasing uuabsr or newepaper reports la the months of Septeaber end October, have illustrated the generally herald levels of PCS material contained la both rish and wildfowl. These reports do not, la general, specify what type or PC3 end/ .or vhsrs the tlsh/wiidrovl samples have beea taken or when. Some fish samples mentioned the Lower Hudson, Tappan Zee area. Thus I aa lead to Infer that my prior documents provided at SPA hearings and CAC meetings have tended to he sustained. If there is any confusion on this, I must regret my apparent lack of olarity. In addition, a 03 Dept, of Int., Geo.Survey "information Rele ase" dated Sept. 14,1981 Indicates a report "Polychlorinated biphenyl transport In the Hudson River, Hew fork was received by me. It Indicated review copies available In Albany and pur- cbaasable copies from HTIS at cost. Helther alternative was an option available to me at this time. Prom the description, I must assume the report Is strongly associated with figure 2-3 of the VTSS2C- DEIS, Sept.'SO and Its replication In EPA-D2IS, May '81. Since I have previously submitted comments shoving the deereasing PC3 flow over the time frame of those charts, there Is no reason to review that analysis here. As a result of that prior analysis, I strongly doubt the current (1981 t 1983) validity of the 7 lbs./day (providing about 25dO lbs/yr) passing Waterford. Hor would I argue against. It for years orlor to 1980. ' ` It seems, that data developed mainly prior to 1979, Is assumed to hold continuously for the future. Tet not of the facts avail able for review confirm that assumption. As I have shown In prior documents, all factual data shows descreaslng flow of PCS aaterlal. One can only conclude, reasonably, that as the upstream sediments and remnant materials became saturated with discharged PCS Isomers, that never additions vent further down stream to fresh absorbing material, l.e. organic and sediments. Thus, a report showing a current level of 7 lbs(?CS)/day flow ing past Waterford must be Indicating either the "mystery" sources fresh additions to the river due to Illegal dumping or leachate from contaminated ground water flowing Into the Hudeon resulting from historical land-fills or similar sources. Dlreetly related to the 2PA-2IS Supplement, Ref., e few obser vations may be In order. - Page 1-46: In my prior papers to SPA st el, I havs Illustr ated ths.faliacy In ths correlations between PCS and "Cs Xoa, of course, have Dr. Saunde?"s letter of Wane 28th to me confirming that hhe radiological souree is actually unknown arcspt. as a gamma ray emitter. Hence, Item III -16, page 3-24, Comment 6 Response, Is Irrelevant In terms of Cs and Is further misleading due to the criteria for concentration of gamma ray emitting material MONS 0 0 9 7 2 * 2. ' associated with dredged matrial at the laa; alta. Ia this mattsr, I nots, that prior to 1970, low level nuclaar wait a possibly Including soma traasuraalc material and uranium, was bain? collactad aad eoatalnad at tha National Lead alta, la tba Albany,N.T. araa, (Slaea than It sbould hata baaa saet to Idaho Palls, Idaho or Slehland Washington. I as than foread to eonaldar tha potaatlal gamma raj souroaa to laeluds tha pcsslbla nocturnal dumping of sued waita in tha Upper Hudson.7rom tha logic associated with such aetloas, It Is aaslar than mak ing tha long haul or pajlag deposit fees? Certainly, it is not unheard of aad aaj be Just as readily conjectured as a gamma ray source, as "bomb fallout". i Sage 3-25 Item III-17, Comment & res pins e. mis discussion completely Ignores the effects of high temperature cooking of :tha ?93 contaminated material. This, In tha lower Eudson, would olearly occur la the "cooling water" associated with Indian Joint as wall as to eaters of fish taken from the river. 7urtber, the reeponss, Ignores your prior discussion of the subject in ESA-113 Hay 8T, Appendix A, page A-16. Tour reply also Ignores ths dioxin compound. Eeeent fish studies on fish In that area tand to confirm my earlier oomments which Include dioxins, and which youZ Ignore. _ Pngs 1-58 Sect. 0 Items 2 & 3; and attached Poughkeepsie Journal Items of 7/5 and 7/22/81/ Item 2 and the 7/5 article reassert the short movement of disturbed sediment and the difficulty of desorption of the attached PCB material. Tha 7/22 article, provides fof tha emergency water protection If PCB lnereaaes should occur. Item 3 of Seot. 9 asserts - "The return flow from the spoils lagoon represents ths largest potential loss of ?C3 aad solids from tha dredging process." I agree with both positions and hence conclude that - BEEPSIBS IS H0B2 EA2HSCT TEAS LEAVING IT AICBET COBCIUSIONS (1) I oontlnua In my position that sines the major portion of PCB material has long since pasted ofer the dam or been volatilised, the proposed dredging portion of this project le not likely to Improve any axletlag situation. (2) Bo factual data, provided to date. Illustrates any poten tial In future years, for significant change la the tower Eudeoa. As shown In prior papers of mins, tbs closer one gets to m.p.O ths lower ths content of the Lester liomers of the Aroelor mixtures exists. Heavier isomers alto do appear to hava longer lives end persistence. Sines however, Aroelor 101S le said to he the principle mixture purchased, and hence presumed to be the waste, from 1972 onward, Its consequent existence since 1977 In the Upper Hudson has bssn olearly diminishing. Aroelort 12A2 and 125*, principle^ the higher Isomers, would havs achieved relative stability In tha 12 to 13 years sines 1971. Hsnes, ths lack of effect at m.p.O axoapt for lamchate and other Lower Hudson soureee. E-35 HONS 009725 3 (3) The entire project appears to root oa an assumption that PC3 flows aad rslated criteria existing ortor to 1579 will ' eoatlnus to bthavs la the same war. this is simply not eras. ' Had these proposals bssa achieved la 1976*1577, soae of the desired effects sight have been achieved. 2ut, ia my opinion, la 1982-1983 the opportunity for lmproveeent has basically beea lost. (4) In the course of this CAC program, I have beea repeatedly asked why I Just didn't accept the experts Judgements. 1 eaa only reply with the observation that I felt the CAC was created to examine those Judgeaeats. Then 1 further ask If they have bothered to read the material I've prepared, I find that shortage of time and other considerations'have not made that practical. But having mainly written to fulfill my obligation to the SPA, I can only suggest that we all seem to have 012? ovd ogoBdftSe Kino Is to provido o rooson~ obi# onolyvlft from tho factual data provided and studlod by myself. (5) In ay response to Sr. Bander's letters to re of June 2$ d 28, I stressed that I was interested in dealing oaly with the factual material. I do not find myself concerned with more politically oriented aspects of the decisions. Oa the factual basis, aothlag proposed shows any real sol ution to the PCB contamination of the Upper or Sower Hudson. The factual data does Indicate that current "Hot Spots" are being burled In erosion sediments at a reasonably satisfact ory rats. And that dredging may well erovlde nothing more than an artlflaally Induced scouring effect. (6) On the basis of the factual material presented aad used, this project seems to result In potentially more harm to the Vaahlngton Cty. environment than the "So-Aetlon with normal SOT activity? Efforts to cover over remaining remnant deposits and make progress with the major landfills seams to provide the greatest benlflt to the nashlngtoa County environment. The simplistic belief that partial dredging of thp Upper Hudson will relelve the contamination of the lower Hudson, particularly at m.p.O aad nearby, has no basic Justification other than the wishful hope that It be so. Lower Hudson contamination might be better served If more attention were paid to the chemical content of organic residues passing through the Indian Point cooling processes. E-36 HONS 009726 * Svtm'X Millerfl*X>8- lHO*) JnhnC. Mhum l*wv X<ilinJ, KMh iWmiwrti n, Fimi. Jr. Kh-rtLrntff.J. MILLER. MANHIX. LEMERY s KAFIN. P.C. ATT01NEYS AND COimSEUMS AT LAST llCl&ESTSR STWffET --------- GlexsFaua. Nmr York iimoi r.o. Box ra (3ii r'i-<jou Joseph M. Walsh June 10, 1981 (815) It i7M UifflHWttlM rmiiinii (S15MMM517 !> l T-' i 7+ r' * r*. f. Ms. Karen Scaizi CEASE, INC. rd n PO BOX 193 Fore Edward, NY 12322 Dear Karen: Re: Funding Contingency Flans - ?CB Drecgina a Encapsulation Project Pursuant to your request, hare is a brief summary of se-eral potential methods for funding contingency plsr.s associate-; with the PCB dredging ana encapsulation project Please note these are 'theoretical" in nature; as of this time -e do net Knew if any of these mechanisms could find practicable application. 1) Line Item on Annual au.-icet This is probably the least accec able alternative because it will be subjected to political influences of changing legislatures and governors over the years. This mechanism could, howeve , become mere meaningful if the federal funds tc be granted were made contin gent upon New York's promise ti provide fundino nn a yearly basis for the life of tne -roject, with a.n additional stipulation that if the State annual appropriations discontinue for env reason prior to the permanent dit >osal oi the l-C3r, 'the State wxll immed iately repay the Federal Cover meant the amounts Initially advanced, with interest. my portion of . an annual appropriation not expend*: in a given fiscal year shoui be eurrarked for a trust .end, to accrue interest thereon, and ,a used in the f .ture if neces sary . 2) Creation of a Trust or 'Suoer" Funf: Rather than rel - on relatir -ly small, ar-iual line item ippropriat.rus, the Strte could appropriate several large am ants over a t -riod of several years to be held in trust for the exclusive purr -se of E-37 MGNS 009727 funding annual maintenance costs and building up a reserve for and in the event of the occurrence of the "vorst case" contingency - ground water contam ination. The major advantage of this mechanism is that it will not be subject to the political whims of future State legislaturesand governors. Once again, lobbying to get EPA to condition the project funds on New York setting up a trust fund would further facilitate the implementation of this or any other funding mechanism. 2) In.,... ir.s.i : The. State could purchase insurance to cover the various potential risks the prefect poses to the environment and public health. I have no iiea if the State or Federal Government wi.il be able to readily obtain such insurance. In theory, ar.y risk can be insured. insurance can be a very flexible funding mechanism. For instance, tl.e Scate could insure against on!/ some ris'-s while acting as a self Insurar wich icspe -t to a.i others. Sim:iarly, the State c- aid have a deductible" policy, whereby the Stata would b liable for the f.rst "x" dollars of claims and the insurer woul be liable only tor claims in excfc.3 of this deductible amount. 4) EFA to ct as a Stroty: A remotely possible fundin i mechanism is getting EPA to agree to act as oh. surety, or guarantor, of 'Sew York State's obligations with aspect tc funding the monitoring and contingency pli.-.t.. In the avent 2F.\ is called upon < . ; orform tie financial obligations of the State, it would have "the right to seek reim bursement '"mt th > is rioht of reimburse ment will obviovs iv a t provide r ich if an incentive for EPA tc egret ! j .act as 1 nunruntor. Or. ..is other hand, the argume it cr. be rats that if tae Federal Government is .:lling to f ir i and approve the project, it ought tc be wil._ng to ins :r-- the health and property of those citizens v st li.kel to be adversely impacted by the projec . Th.s cestur' on the part of th# Federal Government wo .id at least he.a to instill public confi dence and tru c in the projei-. 5) Creation of an Snforcaafali Contractual Undertaking: A somewhat m vel approach wou d be for D~C, on behalf of the Stat , to enter Into % formal contract with EPA E-38 HONS 009728 > . Page 3 riMi, me. Juna 10, 1901 rv `Vv ^ or soma other entity, where the terms of the agree meat evidence an intent to benefit or compensate the residents of the project area in the event ing>leaantation of contingency plans becomes necessary. This would, as a matter of contract law, give rise to the right of pro ject area residents to enforce the contract for their own benefit. This would also allow the EPA or other party to the contract to enforce the contract on behalf of the project area residents. The disadvantage of this mechanism is the need to enforce the contract by means of a law suit- - a ootentially expensive and time con suming endeavor. r^I S 41 J -jm S "r The- above funding' mechanisms are th >se which immediately come to mind. Undoubtedly, there are other more elaborate mechanise*, inclu ding combinations of the above mechanisms. The above should, however, serve as a discussion vehicle to get DSC and CPA thinking along such lines. Another significant task 1* to determine as aarly as possible ` a what the dollar figures ara for ea.h of the proposed cor-ingency plans, 3 aa tha dollar amounts Involved may have an important bearing on which "^L of the funding mechanisms can oe realia.ically employed. ' I hope the above will be of s ice assistance in helping CEASE to begin developing 3ome sound proposals. If you have any questions on the above, please feel free to contact me at any time. . "Sincerely, ' MIL.7 ER, MAr MIX, LI MERY KAPIM, PC JMW/cmb t Joseph M. Walsh I 4 ,4 * * E-39 HONS 009 729 P.D. *1. tast Sire Jtead Tart Idward, aw rorJk September 2S, 1911 Ms.. 1labia Hahn, Project Officer Madsen Miver Reclamation Demonstration Project tarimr-it*! Protection Agency If Tederal fists Mm* Fork, Mv rork .077* Dear as. soOni X ke*a CJiraa comments to make in legend to the Supplemental Draft dated August 19*1. . firstly, 3n Pa?a A-P the 2uc paragraph says the people oX Washington County should be Assured by Mem Fork Stste's status as a sal/ insurer, that the poet- eloeure teguiraumnts mill be carried out. this self-insurer status should . also be suttlcient to eovar any Xutare claims of daaaya that the people may hare, this is unacceptable. x an enclosing foe inclusion in the formal caamenes the letter of June Id from CSASX's attorney. X know that you presently bare bean banded this letter, but X wish to formalize this transmittal. OtC'a past performance in our area necessitates a aore formal eoamtitment to contingency funding than is presently stated in the Supplemental draft. The Carter fond freject, undertaken by DSC in conjunction with the Haterfool improvement Assn., in the Toon of Greenwich, Maskington County, is one case X mould like rt(tranced. ZD this case DSC allocated funds tor the creation of a wildlife habitant and nature trail system for Washington Cooney. Tha project was completed and now the dam has baccate unstable allowing flow to increase too much. DtC now saya that no funds are available tor the maintenance of said dam. Z fear that the aasa aay taeoaa eraa of Site 10 maintenance. Secondly, Z find the Bock Diking of Hotspot SI referenced on page A-f unacceptable. This rock diking would create a swamplika breeding ground for aosguieoee end alter the river SO as to make this area a non-product!ve backwater with no flew. Pre sent!y, we have blue herons, meHerds, black docks which aaae la this area, as well as extensive plant life which would be endangered by this diking project. zBoyce Thompson atetee *axes Judged not to present major conflict." Z disagree. As a basis of disagreement, can attest to the improvement of this area over the last three years. X feel stopping the flow by diking would be disastrous. HONS 009730 na. Robin Mobn, CM Pay. 1 Sapzambaz 23, 1911 Additionally, eh* naad tor a eielzans ovasairbt coomittaa oomptiaad ci both aambara of tbm TAC and CbC is aaaantial. Allhourh eba tac baa eh* inimical axpanisa, eh* local eltixana axa anaif and would lava eh* ability lo spot pxoblaam on a tlaaly baaia. Thank you fox your situation er tbm abova naStats. ' 'Vary truly your*. Ksxan Scolrl Citizens Advisory Committee Sac. cct Sr. Jemem OeSolt, Z2KO* ^ j ^M7*Wr*<W ^ ------ / - -6 ^ /& /iTU&f/y f\----- --40/!sZt&'si ^ E-41 HONS 009731 Ln Lf I /\ ENV,n0NMENTAL RESEARCH, INC. POX PLAZA, SUITE M2 13M MARKET STREET SAN PRANCISCO, CA J4102 TELEPHONE (41S) M1-S4SP 5 October I9S1 .Chief, Environmental Impacts Branch USEPA -- Region II 26 federal Plaza, Room 400 New York, NY 10278 RE: Hudson River PCB Reclamation Demonstration Supplemental OEIS Oear Chief: Subject OEIS recommends land disposal of PCS contaminated dredge spoils from the Hudson River. I agree that removal of PCS hot spots Is desirable aid urgent, but I wish to express concern over land containment of such material. Land storage Imposes a lengthy committment to monitoring of the Of the containment site and a long-term risk of dissemination into the environment. Compliance with the Section 115(a) provision that: *1*0 pollutants removed pursuant to this paragraph shall be placed in any landfill unless the Administrator first determines that disposal of the pollutants In such landfill would provide a higher standard of protection of the public health, safety, and welfare than disposal of such pollutants by any other method Including, but not limited to, Incineration or a chemical destruction process.* could avert the necessity of land storage of the PCB-contamlnated material. New chemical methods of PCS degradation are being announced every week. These methods should be examined and, as appropriate, tested to determine their applicability to the material In question. Even If Initial costs are higher, the long-term costs may be lower because there would be no need for containment site monitoring. Sincerely S8/hs Selina Bendlx, Ph.O President HONS 009732 ENVIRONMENTAL CONSULTANTS . E-4Z APPENDIX F NEH TOW 9IHE HAZARDOUS IASIE FACILITY SITING BOARD DECISION HONS 009733 F-l STATS OF HEM YOBS INDUSTRIAL. HAZARDOUS WASTE SITING BOARD CERTIFICATE OF ENVIROK1ENTAL SAFETY AND PUBLIC NECESSITY || Tha Industrial Hazardous Wasca Siting Board hereby issues this Certificate of Environmental Safety- and Public Nacaasiey [upon the terms and conditions aae forth balow. - . Permittee: Division of Water . New Toth State Department of Environmental Conservation 30 Wolf Read . Albany, Now York 12233-0001 . . Dascription of tha Project: The applicant'a projact consist* of dredging a portion of tha Upper Hudson River between Lock 41 of tha Champlain Canal and Fort Edward, Haw York, and encapsulation of tha dredged notarial in a specially designed and constructed secure landburial faci lity to be located on a 230 acta site, 2.3 nilaa south of tha Village of Fort Edward immediately adjacent to Route #A. Tha purpose of tha dredging project is to remove river bed sediments contaminated by polychlorinated biphenyls (PCBs). The applicant has identified A0 PCB contaminated "hoc spots" in the. Dppar Hudson River as a result of a number of years of scientific and engineering studies. The term "hot spots" refers to areas of river bad sediments containing 50 aicrograms per gram or more of PCBa. Tha location of chase "hot spots'1 are shown on naps contained in the DEIS (Exhibit 36), Malcolm Pirni* SEQR DEIS dated September 19S0 (Exhibit 17) and tha Phase 1 Engineering Report by Malcolm Firnie, dated December 1978 (Exhibit 4A). The "hot spot" dredging projeet, as originally conceived, included removal of tha A0 "hot spots" and 2 remnant river bank deposits, located above tha former Fort Edward dam sice, with encapsulation in a containment site. As originally designed, the containment site for the PCB contaminated material would have had capacity for all of tha A0 "hot spots", tha remnant river bank depoaics land three New Tork State Department of Transportation dredge spoil areas. In addition, a segregated cell at the containment site was to be provided for the contents of three abandoned industrial dump sices located in Che Fort Edward area, but this was not included in the cost estimates for the original "hoc spot" dredging project. The cost of the original "hot spot" dredging project was estimated at $40 million based on construction of the containment sic* in 1981, and a two-year dredging program during 1982 and 1983. I . --- -- F-2 HONS 009734 I ! 1 Subsequent to che development of the original fall-scale project, the applicant was forced to rescope the project due to funding constraints. Total funds available for the project at Chis cue are 926.7 million (920 million in Federal grants and $6.7 million in Stace funds). As a result of chis funding constraint, che applicant' has rascoped che projecc by reducing che number of "hoc spots" to be dredged, .deleting provisions lor Che disposal of the ronant river bank deposits and the material in che DOT spoil areas-, and reduced che capacity of tha containsent site. Reductions vers also made in' the proposed levels of research studies. Therefore, the "hot spot" dredging project, as it presently is proposed, included the dredging of at lease 20 "hot spot" areas with continuation of dredging of additional "hoe spots" until projecc funds are exhausted. The earliest that dredging will taka place is 1983 as che applicant has stipulated that these will be no-dredging of "hoc spots" during 1982. Dredging of "hoc spots" will be performed by either clamshell dredging with hydraulic pumpout unloading or hydraulic dredging and transport as described in the Dredging System Report #2 dated Sep timber 1980 (Exhibit 18) and the Containment Site Investigation Report #1, dated May 1980 (Exhibit 19) and as required by tha Department of Environmental Conservation regulations governing che construction and operation of sacura landburial facilities (6 NICER Part 360). Sonditionsi Sae Appendix A. > issued by the Industrial Hazardous Waste Siting Board on the 22nd day of April, 1982. . . . Effective date* Mky`1, 1982. 1H WITNESS WHEREOF, che Industrial Hazardous . Waste Facility Siting Board has caused chis Decision to be signed end Issued and has filed che same with all maps, ' plana, reports and other papers relating thereto in tha offices of the Department of Environmental Conservation in Albany . this 22nd day of April. 1982. INDUSTRIAL HAZARDOUS WASTE FACILITY SITING BOARS \ Richard A. Parsico t. F-3 HONS 009735 VI. MXNORXTT REPORT HUDSON RIVER PCS RECLAMATION PROJECT STATEMENT TO DEBT- CERTIFICATE OF NEED The Department of Environmental Conservation (DEC) has dona a superb scydy of cha problem of PCBs In cha Hudson River sediment and has pxoposad a workable pxojaec coxanovt 30 Co 331 of cha PCBs iron cha channal above cha Troy dam. (Hoaxing axhiblc 36 - Fadaxal Dxafc Enviroiaental Impact Stacananc Tabla 2-7 and axhiblt 23) Tha dredged amterial is Co' ba deposited in a secure eonCainaMnc sica in cha Town of Fort Edward. Tha cost of.cha pxoposad pxojaec is 26.7 alllion dollars. Tha environmental conservation law (ECL Saccion 27-1103.3(f) sac up a board conslsclng of xapsasanCacivas of five New - Tork State departments and Chxaa oucsida members co review cha pxojaec. This board Is Co deny Issuing cha required eaxcifleaca of need if le finds that "cha facility Is noc necessary or is ochervisa noc in cha public interest co ba approval". Tha purpose of this document is co express cha position of aaobars of this.board who feal cha eaxcifleaca of naed should ba denied. y - . POSSIBLE CONTAMINATION . As a xasulc of testimony by Dx. Edward Buckley, cha board daeldad chat cha risk of adjaeanc exop eoncaolnadon free PCS volaeilised during filling of cha sica was great enough co require permit condlcion #11 Which purchases, ' through an easement, all crops within a spacifiad axes from cha sice. Testimony by Scaven P. Maslansky (of Malcolm Plxnie, Inc., cha pxojaec engineers) indicated chac cha clay on cha alee id noc homogeneous (Volume 8 of Tasciaony, page 38) bue rather has horizontal layers of "a fine sand varve that nay ba in concacc with cha shale rock. Ac presene, cha shale rock is acting co push cha wacer away from cha sha-la into Cha clay. Of course, we'va said chat'chare Is cha pocancial co reverie chac gradianc by cha conscruccion of cha sice". (V8, p. 46) These remote risks of air and wacar contamination would noc axiic if cha pxojaec is noc undertaken. HEALTH Whan Dr. Lao J. Hading, Director, Division of Environmental Healch, NTS Depc. of Haalch, who has bean associated with F-4 MONS 009736 the project since Che GE hearings, was asked what la tha single boic important justification for carrying out the project, ha discussed two raaaona. First "It's essentially cha national policy of tha D.S. to make all watars ivlmabla, drinkable, and flshable". Tha Federal Water Pollution Control Act has a similar.but seemingly unachievable policy of "(l) it i* cha national goal that the discharge of pollutants into tha navigable waters be- eliminated by 1983". Second, "there Is a Health Department policy because, of the health unknowns, and problems of doing risk assessment with these . type of chemicals to reduce human exposure to these chemicals to tha extant 'practical'. (V?., p. 19) He believes "I think always 'practical' impll... a dollar limit". (V12, p. 60). With os without the project there will be a PCB intake by humane from food and air. (p. 43) The present project area's PCB levels in the air (around 0.02 ug/m|) is only 202 of cha average suburban level (of 0.10 ug/mJ) (V12, p. 11) and is less than one tan thousandth of tha current OSHA standard (V12, 84). The NIOSH study on 2300 PCB workers found no increase in overall cancer rates la workers exposed to air with a PCB level at. average of more than 100 class the level found in the project area (712, p. 41). , i -. Except for a short time in 1976 in Haterford, the PCB level measured in treated water in communities drawing from tha Hudson Biver are well below the recommended health standard (V12, p. 78) and in Waterford in the past year has been lass chan detectable, (V12, p. 43) - WATER QUALITY AND FISHING ISSUE In the Federal EIS (exhibit 36) the proposed project is assumed to remove 30Z of the PCB above the Troy dam for an est&Mted exhausting of the PCB above the dam by the year 2008. (Table 2-7, pages 2-13). If no action is taken other than normal navigational dredging end volatilisation, cha Federal' EIS estimates tha exhausting of cha PCB above tha Amm co occur in 2013 or only five years later. Thus undertaking this project would not appear to significantly improve the water quality or allow the removal of the warning .against consuming fish taken tha Hudson River much sooner than not undertaking the project. WATERWAYS DREDGING Hr. Joseph R. Seallato. Director of DOT'S Waterways Maintenance. Division, testified chat in the pest five years DOT has not dredged any sediments which exceed 30 ppm PCB (717, p. 82 6 87) or had any problems obtaining DEC water quality permits for dredging. (V17, p. 66) He says chat tha present method of adding a flocculation agent to the F-5 HONS 009737 dredged water raaevaa 90 co 95Z of cha PCB (V17, p. 76) Ha cacaa chat cha dredging ha* been vary carefully monitored by Cha DEC (V17, p. 55) and would require an EPA waiver If sediments exceed 50 ppm PCB (V17, p.71). This seen* Co rafuca his prefiled testimony of pretjaee naad chac 'If cha project 1* not cooplacad, I believe chac lc will ba difficult and parhap* lopoaalbla to dredge cha canal bacauaa of dradaa disposal problems." (VI7, p.17) . DEMONSTRATION PROJECT aa a URBAihv__lela_rlb__eC_dh1 aCsraslwe-a-i-s-n--u--ps- owDn>s-e--m-m---o-e-n-r-si-c-t-r-a-i-ntio- pnreoeP_c_re_oaeje_d_ci_ntg7 wt_ h* iethMtohreeapr ruo's1 aitci*'t 1*. an excel lane anal lat seal* demonstration of a PCB concainaenc sic* and cha DOT routinely demonstrate* thac chay can dradaa cha river bad. FEDERAL. GRANT Ic should ba noced chac if eh* cerciflcace of naad is not issued, cha $20 million of Federal granc funds allocated co chia project nay ba "lose". Thera is always cha possibility thac nonay noc spent on this project will b* spent on sons ochar project of even lass value in soaa ochar scats. Nevertheless, we. have co continue co have faith chac our aystarn of governasnt has the Integrity co spend our nonay wisely or not spend lc ac all! SUMMARY We recognise there me valid reasons co hava initiated cha projecc study. However, having reviewed cha record, us, cha undersigned members of the board, feal that cha applicant has failed co prove chat cha facility is nacassary or otherwise in cha public's best interest. Therefore, w* respectfully find Chat cha certificate of need should ba denied. PETER S. KENT NNAATTHHAANN Gg7. DDIICCKKIINNSSOONN,, JJR5. F-6 HONS 009738 COMMENT OR SITING BOARD It la our opinion chat every aaabar of Cha board acted with ineergricy and good eonaeleaea that hla daclaloa to approve or dlaapprove chaeertlficaea of need uaa dona for tna beat lncereac of Cha clclzana of Raw Tork Staca. Wa faal thap, co broaden cha acopa of fdcure boards, two representatives from cha educational field balancing an aqual nuabar of acace an ad hoc members should be considered auch as proposed In NTS legislative bills A-9725 and S-7872. F-7 HONS 009739 APPENDIX G COMPENSATION PLAN FOR FARMERS G-l MONS 009740 COMPENSATION Background Attachment # l While expert testimony Indie*ted thet contiguous residential populations would not be endangered, vegetation, particularly crops grownlng within one-half Mile from the encapsulation site, could be detrimentally affected by airborne PCB. The applicant since early In the development of the project, has recognized and accepted that It has a responsibility to provide just compensation for damages resulting from such airborne materials. The need for such a plan was also highlighted by the U. S. Environmental Protection Agency both In the Federal Draft Environ mental Impact Statement and a letter by Acting Regional Administrator Richard T. Dewllng dated August 17, 1981 to Commissioner Robert F. Flacke In which he stated "...the possibility exists for some crop contamination In the affected area. Notwithstanding the operational measures which are being developed to mitigate the Impacts of PCB volatilization on the surrounding area, NYSKC should consider how to protect the farmers from financial losses should their crops become contaminated during the operation of the containment site. . This concern has been expressed many times during public . meetings and hearings and EPA agrees that the farm families and their llvel Moods should be considered during the operation of the project. A financial assurance plan could be developed to protect the agricultural Interests as part of the overall project contingency plan.* On October 6, 1981 the applicant met with approximately 28 fanners/residents or agents thereof to solicit further clarification of compensation issues. At that time the applicant distributed a G-2 HONS 009711 survey/questionnaire seeking specific Information relating to the Individual parcels of land surrounding the encapsulation site. One spokesman at the. nesting strongly urged those present not supply the Information and despite repeated requests for the Information, Informally and on the record, to this date the applicant has received only four responses. The Siting Board throughout the course of the Hearing Indicated the necessity of a compensation plan. Based on the record, as well as discussions with the farmers. It Is apparent that due to the farmers' financial arrangements and the fact that crops cannot be Instantly created, It Is Important that compensation be made In a timely fashion. The applicant recognizes that the general rules of compensation require an actual loss as opposed to one that Is speculative. The applicant recognizes the need for compensation prior to actual losses. The Siting Board In an effort to develop a complete record requested representatives of various agencies to address specific Issues of crucial concern to this project. On the last day of the hearing, representatives from three of the four agencies requested supply Information appeared and provided Information In their respective areas of expertise relating to this project. . The Otvlston of the Budget, Executive Department of the State of New- York, was represented at the hearing by Mr. David Googlns. He serves as the Deputy Chief Budget Examiner. Mr. Googlns addressed the concern about the State's long-term commitment to this type of project In light-that one sitting* G-3 HONS 0097Vi legislature cannot cosaalt a succeeding Legislature. Ho states that maintenance and perpetual care of a facility as this Is a function of the State's stability and the longevity of the government Itself, and by the State's eownltment to Its social obligations. . Another concern addressed by Hr. 6oog1ns was the State's ability to respond quickly and adequately to emergency situations. He mentioned the extraordinary resources available to the State as was demonstrated during the Thruway accident of December 23 Involving a truck that spilled hazardous waste. Within minutes. State Police were on the scene, with members of the Department of Health arriving within the hour. Within the first 24 hours of the mishap, 25 man days had been provided to the site. - Similarly, on April 19, 1979, the State wes faced with an emergency situation when the vast majority of the State's correction officers walked off the job. Within hours. National 6uarrhaen assumed tasks normally undertaken by the correction officers. Twenty-four hours later, 8,000 troops were manning 25 correctional facilities anround thk State. _ .. Hr. Googlns explained that the State possesses a financial Interest In maintaining a properly run facility. In the case of a demonstrative default, the State Is subject to a suit by the Injured parties. If the State did not pay the settlement fee ordered by the court In the case of such a suit, It would then be subject to interest on the amount of. monies not paid. G-4 MONS 009743 Hr. Googlns also notad that agriculture business Is the largest single Industry In the State of New York. If the Departeent were to request funding to pay farmers for projected losses (anticipatory losses determined by experts' findings). Hr. Sooglns felt that such funds would be approved. Finally, Hr. Sooglns stated that If pressure was put on the Comptroller to give the Issue priority, then farmers could receive funds from the State via the temporary easement process In one day. Compensation Is thought to be the only viable alternative for farmers In the region because of opinions expressed by Hr. John Kerwln, Chief of the Bureau of Insurance, Office of General Services. Hr- Kerwln stated that It was the general policy of the State of New York not to Insure its buildings, contents or other properties. The only forms of Insurance purchased are automobile and boiler (where Inspections are required). G-5 HONS 009744 The Area`Affected Based on tha expert testimony, It Is reasonably projected that an area 700 eaters from the point source eay be subjected to deposits free airborne PCB so as to exceed the USDA standard of 0.2 parts per million in crops. The result could be characterized as an encroach* nent which constitutes a taking for a public use and for which the owners and lessees must be compensated. The exact area subject to actual PCB deposits that exceed the standard Is subject to further study and field survey. Weather station data Is essential for this growing season so that the degree and range of PCB contmelnatlon can be calculated during next winter. No detailed arrangements for financial compensation can be finalized until these predictions are made. G-6 HONS 009745 Hal no ef Payments There ere four potential approaches to conpensatlon for affected parcels of land (1) payment of the estimated loss, (2) payment of the estimated loss with provisions for adjustment, (3) payment for actual loss and (4) establishment of a buffer zone through temporary easements over the area for which contamination Is projected. The applicant finds alternatives one, two and three unacceptable. Payment Is estimated losses may well not reflect the true situation, thus either providing a gift to the farmer or inadequate compensation depending on the particular circumstances. The state Is constitu tionally precluded from paying speculative compensation, while being mandated to provide full coapensatlon for damages It Inflicts. As Indicated earlier, the financial situation of the farmers makes alternative three less than satlsfkctory. Should compensation net be paid until after the crops are grown and contamination proven. It would be too late In many Instances to obtain substitute crops In a timely fashion. Such a situation could easily force the farmers, who have a cash flow problma, out of business. Alternative two Initially appeared to be acceptable. However, the approach Is untried, requires agremnent, and requires continued negotiation for the duration of each particular agreement. As Indicated earlier, there Is an Indication that reaching such agreements may be Impossible, and most Importantly, the payment would have to be made on an annual basis. The applicant recommends alternative four. S-7 HONS 009746 The concept of a buffer zone`ms t logics! result stealing fro* the concern over the deposit of airborne PCB fro* the disposal site on adjoining lands, which are primarily dairy farms. The concern Is the threat of contamination that PCB pose to the cattle and other livestock by virtue of their Introduction Into the food chain. The buffer zone Is Intended to prevent this contamination by eliminating agricultural use of lands within the buffer zone for a period of two growing seasons beginning with the season during which dredging will begin. The buffer zone will be established by the use of temporary easements. These easements would vest In the Department the right to use and occupy the site In any manner necessary to Implmnt the buffer zone concept, reserving to the o*mer the right to main tain and use any existing structures and such other uses of the premises as the Departeent may permit. Present Indications are that neither the growing of crops nor the pasturage of livestock will be allowed but that residential use will be permitted. Further refinement of the right to be acquired and the language necessary must be accemplIshed through negotiations between the applicant and the owners. G-8 HONS 009747 By law, the applicant is required and desires to justly couponsate the affected outers. The owner affected should be determined conservatively that Is use a minimum of one-half mile (2640 ft.) from the point source as opposed to 700 meters (2298 ft.). This distance will be Increased If testing results indicate the need. This area for labeling purposes should be characterized as a buffer zone. Where the projected buffer 2one boundary would Intersect a field resulting In a silver parcel, the entire field should be Included. G-9 HONS 009748 Scope of Compensation It Is necessary to establish the just compensation which each owner Is entitled to receive. The traditional measure of just compensation due the owner of land subject to a temporary ease ment is the rental value of the land for the period of occupation. This easement Involves the disruption of a going commercial enter prise wtth the possibility of long-range effects due to the Interruption of the enterprise. Accordingly, any calculation of just compensation must Include an analysis of the following factors 1. the rental value of the land; v'-- 2. the cost of either temporarily relocating the farmer or anlntalnlng his livestock during the period pasturage and crop production are prohibited; 3. any severance damages inflicted on the land which was subjected to the easement upon the return of the land to the fee owner; 4. any damages caused to any portion of a farm over which we did not acquire an easement but which Is a reawlnder of a farm.over a portion of which we did acquire an easement; 5. any damages to the capital-assets of the farmer. The major advantage of this approach Is the ability to compensate Initially for the total projected damages set forth above. This permits the owner to utilize his compensation in any manner he sees fit. G-10 HONS 009749 Secondly, the esteblIshment of the buffer 2one,~through the easement process, permits the Department to control completely the use of the property by the terms of the easement and thus through proper language will prevent the possibility of raising contaminated crops. The principle, permitting the State to purchase property as a buffer zone, has been well established and thus this approach avoids many of the administrative and legal questions encountered by the other approaches evaluated. Finally, under the buffer zone approach, compensation will Include all factors pertaining to the use of the land. Including the values of crops which would otherwise haye been growing. Ml HONS 009750 Identification of Appraisal Problem >nd Proem The applicant has already consulted with an Independent appraisal fins. This first, through an Individual with specific stills related to agricultural valuations will be guided by the following appraisal process In determining Just compensation: 1) each property within the buffer tone will be Individually evaluated. This evaluation will include the following determinations: a) the area of the parcel affected; b) the percentage of the total parcel affected; c) the percentage of land used for com, hay pastures and other agricultural crops affected; d) the type of operation undertaken on the parcel - with special emphasis on severance factors as - that Is appropriate; e) the type and size of the operation and the effect of loss of use on the remaining portion of the parcel. " - As a result of the gathering of this Information which will Include personal contact between the appraiser and property owners as well as the development of all pertinent cost figures and Infor mation regarding operation, an appraised compensation figure will be estimated by the Independent appraiser. G-1Z MOMS 009751 Procedural Stew for*Acquisition of Eiseaents The steps which the sppllcint proposes to follow In order to obtain the easements are summarized as follows: 1) secure approval fro* the Coanlssloner to acquire the easements; 2} have an accurate map and description prepared and for* warded to the Department of law with a request for a Certificate of Title; 3) secure entry onto the premises for survey and appraisal purposes; 4) obtain appraisals and seek a voluntary negotiated aqulsltlon at 100.percent of the highest approved appraisal; 5) In the event a negotiated settlement cannot be reached, the State will proeeed to take the easement by appropriation. The State will make an gffer of 100 percent of the highest approved appraisal and the owner will be advised of the availability of an Agreement for Advanced Payment. This Agreement permits the owner to accept the offer and at the G-13 HONS 009752 sum time provides the owner the right to seek greater compensation for the easement by signing a claim In the Court of Claims. G-14 HONS 009753 Other leoal Remedies Available The proposed pirn compensates for all damages caused by the acquisition of the easement. Owners, where no easement Is acquired, still may bring an action against the State for damages caused by PCB deposited as a result of the project. The Attorney Saneral has concluded that the State can be held libel through suits In the Court of Claims for any negligent or other tortious actions of the Department of Environmental Conservation committed In carrying out the Hudson River PCS Reclamation Demon stration Project. This opinion Is based on the State's waiver of laesunity effected by Section 8 of a Court of Claims Action. The State Is libel for the torts of Its agents even though its agent Is engaged In a governmental activity. (Jones v State of Hew Tort. 33 KY2d 275, 280 [1973]). Furthermore, the State may also be held libel for negligent actions for carrying out a governmental plan (Kelly v State of Kew Tort, 57 AD2d 320 [*th Dept. 1977]). The State, as a land owner, has a duty not to use Its land In a manner so as to. cause Injury to neighboring property owners (Palmer ltd, v State of New Tort. 33 AD2d 412 [3d Dept. 1970]; Poysa v State of Hew York, 102 Msc 2d 269 [Ct of Claims, 1979]). - G-T5 HONS 009754