PCB Contamination of the Upper Thesis

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Additionally, the water intake near Chelsea may be used, at times, to supplement New York City's water supply, during times of drought. The Town of Waterford and the Town of Halfmoon both get their muncipal water supply from the Upper Hudson River ("Hudson River PCBs," 2008).

GE's Involvement in the Build Up of PCBs in the Hudson River

From 1947 to 1977, the General Electric Company discharged as much as 1.3 million pounds of PCBs into the Hudson River, polluting 197 miles of the river and creating America's largest Superfund site. Two of GE's facilities, one at Hudson Falls and one at Fort Edward are reported to be the source of the pollution. As Angelo (2009) notes, PCBs were used as high-temperature insulators in the manufacturing process of transformers and capacitors, at the GE facilities. Even today, more than three decades later, PCBs still leak into the river from GE's facilities. According to Superfun law, polluters are charged with cleaning up the pollution they've created; however, GE has continued to fight the development of a cleanup plan. The organization has lobbied Congress, attacked the Superfund law in court and launched a media campaign stating that the proposed dredging of the river would stir up the PCBs ("Historic Hudson," 2007). However, remediation of the site was slated to commence.

In 2002, the EPA's decision against GE was the catalyst for the organization's plan to remove 800 Olympic swimming pools worth of contaminated river sediment. However, the company procrastinated for nearly four years. The remediation project was scheduled to begin in October 2005, but did not start until 2009 ("Historic Hudson," 2007). While GE instigated protracted legal battles, the contamination continued, moving downriver and spreading the contamination further.

Clean Up Approach

Clean up of the contaminated site of the Hudson River is being addressed in three stages. The first are immediate actions, followed by two long-term remedial phases involving remnant deposits and river sediments. The immediate actions of the clean up approach occurred in 1977 and 1978. At this time, an estimated 180,000 cubic yards of contaminated river sediment were dredged from the east channel of the Hudson River, at Fort Edward, in an effort to clear the navigational channel. These 180,000 cubic yards of sediment, along with approximately 14,000 cubic yards of highly contaminated sediments from a remnant area, were placed in a clay-lined containment cell ("Hudson River PCBs," 2008).

Investigators at Bakers Falls, near the GE Hudson Falls facility, found elevated PCB concentrations in the water column, in 1991. At that time, GE signed a consent agreement allowing the State of New York to further investigate, as well as to take interim remedial measures in order to prevent PCB contamination from the site to enter the river and additional immediate actions were taken. The company took a variety of measures to help prevent contamination of the Hudson River. These included: the prevention of river water flow through seep areas and a mill building that had been abandoned, seep collection system installation, contaminated sediment was removed from the mill building, areas where seeps were found in the riverbed were pressure grouted, and PCB collection wells were oiled ("Hudson River PCBs," 2008).

In the early 1990s, removal of contaminated soils was performed on Rogers Island. Concerns had arisen that the exposure to PCBs by current residents and possible future users of Rogers Island, would be a risk to the public's health. Therefore, the EPA decided to remove the PCB contaminated soils from the northern part of the island, where the residential section was located. This removal was completed by December 1999. In March 2004, the State of New York selected a long-term remedy for the GE facility ("Hudson River PCBs," 2008).

The first long-term remedial phase centers on remnant deposits. GE did conduct an interim clean up of the remnant deposits, per a Consent Decree with the EPA, as selected in the 1984 Record of Decision for the site. The method of remediation chosen for this phase was in-place containment of the remnant deposits located on the shoreline. As mentioned, these remnant deposits were exposed with the lowering of the river level due to the removal of the Fort Edward dam. The process for this remediation included covering the affected area with a geosynthetic clay liner, along with a 2-foot layer of soil. This was then followed with grading and revegetation, as a means of minimizing erosion.

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Rocks were utilized to stabilize river banks to prevent scouring. By 1991, the capping of the area was completed and gates had been erected to limit site access ("Hudson River PCBs," 2008). The actual removal of sediments in the river itself would not see a plan formed for more than a decade.

Finally, in February 2002, the EPA decided that it was appropriate to remediate the Upper Hudson River and the contaminated sediments. The remediation selected includes dredging approximately 2.65 million cubic yards of PCB-contaminated sediments out of the Upper Hudson River. The EPA estimated that there would be approximately 150,000 lbs of PCBs in this removed sediment -- approximately 65% of the total PCB mass they believed to be present in the Upper Hudson River. Of course successful remediation also depended on separate source control action taken at the GE Hudson Falls plant to prevent new contamination from occurring ("Hudson River PCBs," 2008). There are several primary components to this plan.

The river sediments removal project is a much more involved plan. There are several components that have to be performed for the project to be successful. First, river sediments in River Section 1, River Section 2 and River Section 3 must be removed. The navigation channel must be dredged as necessary to facilitate remediation and prevent hindering of canal traffic during remediation, Air quality and noise performance standards must be monitored and kept in accordance with state and federal law. Independent external peer review of the project must be conducted and evaluated at the end of the first phase of dredging. Dredged areas must be backfilled with at least one foot of clean material, in order to isolate the residual PCB contamination, as well as a means of expediting habitat recovery. The dredging techniques utilized must be environmentally efficient, in order to minimize the resuspension of sediments during dredging. Dredged sediments will need to be transported via barge or pipeline to processing and transfer facilities, to be dewatered and stabilized. Once the contaminated sediment is dewatered and stabilized, it will have to be transported to an appropriate, licensed, off-site landfill for disposal. Fish, water and sediment will have to be monitored to determine if the remediation goals are reached. Restoration of aquatic vegetation will also need to be monitored. Institutional controls, such as fishing restrictions and fish consumption advisories, will need to be implemented and/or modified as necessary until remediation goals are met ("Hudson River PCBs," 2008). The clean up process for this phase begins with remedial dredging in two phases.

The first phase of dredging is to be conducted at less than full scale operation. Extensive monitoring of all operations will be included in this phase. In addition, an independent, external peer review of the dredging resuspension, PCB residuals, and performance standards of the production rate will be conducted. With this information, Phase 2 can be modified to improve the results. Phase 2 will include the remaining dredging of the project and will be conducted at full-scale. The EPA will continue to monitor the project and evaluate performance data, in order to make adjustments ("Hudson River PCBs," 2008). Floodplains are also a concern of the project.

Sampling of the floodplains of the Hudson River have been initiated. The initial sample phase resulted in several floodplain areas being targeted for removal action. This removal was performed, in 2007, by GE ("Hudson River PCBs," 2008). The legal battles and planning have been a long, drawn out process; however, finally some progress has been made on the major components of remediation for the Upper Hudson River.

Progress to Date

As Angelo (2009) notes, it has been thirty-two years since the last PCBs were discharged into the Hudson River, from GE's manufacturing complexes. After decades of legal wrangling, on May 15th, 2009, GE began the third, and most costly, phase of the remediation project. The removal of the first 400,000 tons of contaminated sediment, along a six-mile stretch of the Hudson River, near Fort Edward, began this spring. The additional dredging of the 34-mile stretch of the river to Troy will be in the second phase of dredging.

Although GE has not released the costs for the project, the EPA has estimated clean up to reach approximately $750 million. Because the PCBs tend to accumulate in the slow-moving portions of the rivers, such as at bends and turns,.....

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