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PCB POLLUTION IN THE UPPER HUDSON RIVER John E. Sanders Barnard College, Columbia University ABSTRACT The upper Hudson River is one of the nation's most ex- tensively PCB-polluted waterways. Wastewater discharge from two General Electric Company (GE) plants, and erosion of wood-laden, PCB-soaked deposits contributed to downriver supply of PCBs. As a result of a 1976 settlement between the state and GE, PCB discharges were stopped and the state has proposed to rehabilite the upper river by dredging of the PCB hot spots and encapsulation of the contaminated dredged material in a secure facility. Since that time, numerous legal and institutional obstacles--primarily funding and permitting--have delayed rehabilitation dredging to 1993 or 1994. The amount of PCBs entering the lower river has dropped from about 2 tonnes per year in the late 1970s to 1 tonne and less in the 1980s. Yet despite this drop, since 1983 the PCB content of striped bass caught in the Hudson estuary has averaged about 4 ppm. Although this amount is less than the pre-1984 Food and Drug Administra- tion action limit of 5 ppm, it is still double the current action limit of 2 ppm. OVERVIEW OF THE HUDSON RIVER The Hudson River is divided into upper river and lower river where it is joined by the Mohawk River, south of Waterford. The combined river doubles the flow of water and triples the quantity of suspended sediment carried into the estuary over the Federal Dam at Green Island compared with that at Waterford (U.S. Geological Survey [USGS], 19779. The upstream limit of the estuary (the lower river and estuary are nearly synonymous) is the Green Island dam at the city of Troy, at the head of tidewater and about two miles south of the confluence of the Mohawk and Hudson rivers (Figure 1~. An additional factor related to the upper river is the Hudson- Champlain barge canal, a division of the New York State barge canal consisting of 6 dams and 7 locks. The canal enables small boats and barges to use the upper Hudson River between the Federal dam at Green Island and Fort Edward, where it cuts through the landscape in a north- east direction, away from the river, which swings west, then north. 365

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366 A typical profile section across the upper Hudson River shows mar- ginal flats underlain by silt and clay sediments up to 3 m thick and a wide channel floor underlain by a thin (1 m or less) carpet of coarse sand and gravel resting on deformed Ordovician bedrock (Sanders, 1982) In the upper Hudson River, PCB-contaminated sediments attain their highest concentrations in the reach between the cities of Hudson Falls and Troy (Helling and Horn, 1977; Hetling et al., 1978; Tofflemire and Quinn, 1979; Tofflemire et al., 1979; Brown and Werner, 1985; Brown et al., 1988~. Just south of Bakers Falls, the river flows past two General Electric (GE) capacitor-manufacturing plants, one at Hudson Falls, which began using PCBs in 1947, and one at Fort Edward, which began using them in 1952 (Figure 29. Hydraulic Influences Downriver movement of PCBs in the upper Hudson is a function of natural sediment transport governed by water discharge (Turk, 1980; Turk and Troutman, 1981a, 1981b; Schroeder and Barnes, 1983a, 1983b; Barnes, 1987~. A network of gauging stations maintained by the Water Resources Division of the USGS (Figure 2) monitors variations in discharge and extremes associated with floods (Figure 3~. A compilation of maximum known discharge and stage for 326 localities within the Hudson River basin has been made by Robideau et al. (1984~. Empirical studies of the relationship between water discharge and PCB transport into the Hudson estuary, have shown that what might be termed the "high-water mode" starts when the daily discharge at Waterford exceeds about 19,800 ft /se (Schroeder and Barnes [1983b] and Barnes t1987] use a value of 6SO3m /sec). The 100-year flood flow of the Hudson River is 50,000 ft /see at Fort Edward; 110,000 at Waterford; and 220,000 at Green Island (Darmer, 1987~. PCB Transport Starting in the Water Year 1977 (October 1, 1976 to September 30, 1977), the USGS intensified monitoring of the upper Hudson River. Daily samples were collected to determine suspended sediment in the up- per Hudson and Mohawk rivers (winter sampling was discontinued during winter months as of 1980) and intermittent samples were measured for for PCBs to show the range of variations of water discharge. In the USGS laboratory, PCBs may be extracted from the total sam- ple, or only after samples are passed through a 0.45-micron silver- oxide filter. What passes through the filter is defined as '"dissolved load"; what remains is the "suspended load." PCB analyses indicated that two contrasting regimes operate in the river as a function of water discharge. At high flows, PCBs are found almost entirely in the fraction that remains on the 0.45-micron filter, and thus is attached to the sediment (Schroeder and Barnes, 1983b). In general, the more the water discharge, the more the suspended sediment, and thus, the higher the concentration of PCBs (Figure 4~. But additional gauging

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367 N O .Z c, n ~ o: V~~ ~'3: x ;': / CORINT!~) ~ PALMER SPIER FALLS ~ fALLS j DAM ~ S ~ _ D Z r~ C Z ~ O Z O ~ ~ \o ~AK~RC ~ _~N E ~ M ~ ~G' DAM ]/~LOCK, ~ ~/~"! ~ DA~4 LOCK C ~ _ ;~3\~ D ~ M I~__ DAM DAM LCCK 6 SARATOGA _ SPRINGS ~ l LEGEND U.S.G.S. PCS STAT fON - STILLWATER gna~, ~ mr~ ~ arN~;ELAER CO O~M LOCK ~ MEC HANICSVlLL V~ \ _ ~ LOCK M C n ~ ~ 11 , ~ ~ ~ .- fEDERAL O^U ~ U S.G ~ GAGE W' -ER LIEl `" ~ ,,' TROY S~ FIGURE 2 U PPE R H U DSON R IVER BASIN FIGURE 1 The Hudson River Basin; the dashed line marks the limit of subbasin drainage area. SOURCE: Hetling et al., 1978.

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368 N ~ HUDSON FALLS G59 C APUTO l - ace R - E Cal FORT EDWARD DAM(~:EDWAPD FIGURE 2 Glen Falls - Fort Edward area showing PCB - related sites. SOURCE: After Hetling et al., 1978. J ~ ~ - ,alIc Ply MORE AU ~ ~~ ,, 5 A 14 ~ ROGERS ISLAND ! POINTS OF INTEREST ON UPPER HUDSON RIVER GE CAPACITOR fACILITIES AIR MONITORING STATIONS DREDGE SPOIL DISPOSAL SITES o LANDFILLS OR OUMPS _._ ~ By I I fORT MILLER Al 1 3 01)U o 17.~, o U ~ 1 001) V) '~ 10.0(1U UJ [L 9000 - B(~ At lock, ~ 601~) U - C] J _ 4000 _ NOf! O.ecl~a' - 's 1~ Iollo - .ng 1. -1888 lo 1956 Jon R'w~ 1 ~che'`'cwelle origin Con. dra~r~ - ea 4,500 sit ~ 2. -1957 lo 1976 Computed as Hudson Hewn 81 Crn labor man ~~k Revm A Coho !;. eons Id - ed - Swab to Waterbed gaging clalio', 3.- 19)7 lo 1985~14`dson R'wer al Waterto~d oaring station. d~a'.`a' area 4.611 #I mi 3000 ~ 1 1 1 1 1 1090 1908 I'lO 19Z0 1930 1940 AWES __ ~ 1g50 1960 t97O 1980 1986 FIGURE 3 Water discharge of upper Hudson River (expressed as mean daily discharge computed on an annual basis at Mechanicville (1888 to 1956) and Waterford (1957 to 198S). SOURCE: After Darmer, 1987.

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369 stations between Waterford and Glen Falls demonstrated that water dis- charge at Waterford is not a single reliable variable for estimating the quantity of PCBs transported into the estuary. Two floods in 1977 show the possible contrasts. During the March flood, in the lower drainage basin, much of the water entered the Hudson from the Hoosick River, south of the most heavily contaminated area. The ratio of PCBs to suspended sediment at Waterford for the April flood, in the upper teas in, was seven times that of the March flood, indicating that the PCB source was bottom scour north of Stillwater. Closer inspection shows that it came from between Schuylerville and the Thompson Island pool (Turk and Troutman, 1981a; Schroeder and Barnes, 1983b). At low flows, PCBs are found in the dissolved load. However, it is possible that PCBs are attached to colloidal particles, which are small enough to pass through the filter (Schroeder and Barnes, 1983a). PCE concentrations tend to increase as water discharge decreases (Turk, 1980; Turk and Troutman, 1981b; Schroeder and Barnes, 1983b; Figure 5~. Because it was first thought that PCB concentrations would in- crease with water discharge (Figure 4, right side), this relationship was referred to as the "low-flow anomaly." The inverse relationship between water flow and PCB concentrations implies, however, that PCBs are entering the water column at a constant rate (migrating out of contaminated bottom sediments, for example) so that as the amount of water decreases, PCB concentrations increase (same amount of PCBs mixed with less water). The downriver changes in PCB concentrations indicate that the low- flow PCBs are also derived from the reach of the river between Rogers Island (Fort Edward) and Schuylerville (Figure 6~. The low-flow PCBs FIGURE 4 PCBs and concentration of suspended sediment in the Hudson River at Schuylerville, New York, Water Years 1977 through 1982. Lines are best-fit regres- sions for years indicated. SOURCE: Schroeder and Barnes, 1983b. cr 3.0 - cs: 2 0 o A: z 1.( ~ 0.9 0.8 0.7 0.6 Z 0.5 o 0.4 z 0.3 LL z 0 0.2 co Year of sample collection ~ t 977 ~ 1 980 01978 ^1981 0 0 1 979 0 1 982 _' O ,' - ~' v O _^ a/: O 0 / /- - 0.1 5 6; 8 9;0 To To 40 50 70 100 2( ID SUSPENDE~SEDIMENT CONCENTRATION, IN MILLIGRAMS PER LITER

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370 2.4 CC Ad 2.0 Cat In 6 1.6 o Cat - Z 1.2 - z o G 0.8 z z o C) 0.4 I . . ~ V _O O700 800 900 t ooo 1 1 Do 1 200 1 300 HUDSON Rl VER Dl SCHARGE. I N CUBI C METERS PER SECOND Year of sample collect,or ~ 1977 0 1978 0 1 979 1980 ~ 1981 v 00 v ~0 o v ~ O O ~^ O .0 A-- - o . oo of i: :~ r ~ I I 0~750. 3.63) o o o o . . O O v V Van ~ . . _ ~ v v v . FIGURE 5 PCB concentration and water discharge, upper Hudson River at Schuylerville, New York, Water Years 1977 through 1982. SOURCE: Schroeder and Barnes, 1983b. move with the water. Although PCB concentrations during high and flows and generally decreased after 1977, maximum concentration of total PCBs during the high-flow events did not decrease (Schroeder and Barnes, 1983b). The foregoing discussion of sediment transport is important to understanding why computations of future PCB transport into the estuary prepared by Lawler, Matusky, and Skelly Engineers (LMS, 1978, 1979) and based on the U.S. Army Corps of Engineers (COE) HEC-6 riverbed scour model, have been so much higher than observed values. The HEC-6 model is predicated on a stepwise transport downriver from pool to pool. According to the LMS model, PCBs that wash over the Green Island Dam should come from the pool backed up behind the dam. These PCBs would have reached the pool only after having traversed all the other pools ~ ~ ~ - ~ ~ ~ information between Fort Edward and Green Island. For whatever reason, from the USGS indicates that on the upper Hudson River since 1980, a pass-through type mechanism has been dominant (NUS Corp., 1983~. The PCB load transported into the estuary is acquired not from the Green Island Pool but rather from north of the Thompson Island Dam.

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371 8 6 4 6 I: LL 6 o o y z 10 _ Cal A + 78 79 80 81 1 8 6 21 77 78 79 80 81 14 r 18 27 77 78 79 80 81 24 7 15 16 Rogers Island Schuylervi I le 77 78 79 80 81 Sti I Iwater Waterford B Cam g 8 z 6 6 4 l 2 _ o 23124134 78 79 80 81 17 1l 8 6 77 78 79 80 81 Rogers Island Schuylervi I le Sti I Iwater 1 18 27 . 24 ~ L 1 ? 126 1 77 78 79 80 81 11 LULL 77 78 79 80 81 LOCATION AND WATER YEAR Waterford FIGURE 6 Transport rates of PCBs in upper Hudson River during nonscouring discharges, Water Years 1978 through 1981, calculated by multiplying PCB concentration by river discharge at station indicated. Standard-error bars at tops of rectangles; numbers of samples shown within and at bases of rectangles. SOURCE: Schroeder and Barnes, 1983b

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372 Discharge Cycles Some investigations present evidence that the Hudson River and estuary may be subject to cyclic variables. Mathematical analyses of monthly mean flows of the upper Hudson River at Green Island (based on daily readings by the USGS), suggest that several cycles may be pre- sent. Starting with a table showing average monthly flows from October 1947 through September 1975, Texas Instruments Incorporated Ecological Services (TI) summarized various physical factors affecting the estu- ary, with particular attention to deriving a mathematical expression of the varying locations of the landward edge of the saltwater wedge. One factor recognized was changing freshwater discharge. TI found that dis- char.ge data could be reconstructed using five major cyclic components --105, 21, 10.5, 4.2, and 1.9 years--and that All except the last cycle have periods which are multiples of the value 2.1; this suggests an outside controlling influence. There is some similarity to recurring cyles of solar activity, but the relationship remains to be defined. (TI, 1976, p. IV-12) In analyzing the so-called "no-action" alternative as part of the management alternatives explored by NYS DEC for dealing with the prob- lem of PCB-contaminated sediments in the upper Hudson, LMS (1978) fol- lowed the TI cyclic approach. The LMS forecasts of future river dis- charge (the critical variable in trying to predict future PCB transport into the estuary) were made by analyzing the monthly mean flows at Spier Falls (1178N-653E, Corinth quadrangle) for the period 1930-1977 (computed by the Hudson River-Black River Regulating District). These values were then related to the flow of the combined Hudson-Mohawk riv- ers at Green Island, as recorded daily by the USGS. In their projec- tions, LMS presumed that the flows from 1957 to 1976 would be repeated during the forecast period of 1977 to 1996. In a summary of the hydrology of the Hudson River, Darmer commented that Extreme periods of precipitation, either high or low, are of con- cern because of their effect upon the environment. The extreme drought of the 1960's, followed by a series of wet years in the 1970's, imply that precipitation may follow some cyclic pattern rather than being entirely random. (Darmer, 1987) If the flow of the Hudson River is cyclic, it must be a complex func- tion of several interacting cycles. Cycles whose effects seem to be present include the lunar perigee-syzygy cycle of 14 months (Fergus Wood, 1978) and the 19.8-yr Saturn-Jupiter lap cycle (Pairbridge and Sanders, 1987), both of which seem to be reflected in the cyclic orbit of the Sun around the center of mass of the solar system, and thus possibly also in solar output (Landscheidt, 1987~.

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373 Other Significant Environmental Factors Remnant Deposits Removal of the Fort Edward Dam in 1973, exposed what are called remnant deposits, debris washed downriver from lumbering sites in the Adirondacks that accumulated behind the dam (Malcolm Pirnie, Inc., 1975; 1977a, 1977b; 1978c ~ . Wood is the characteristic component of these deposits, which possess a strong affinity for PCBs. Considering their location just downstream from the GE wastewater discharge pipes, it is not surprising that some of the highest concentrations measured in the upper river have come from the remnant deposits. Heavy Metals Sediments in the upper Hudson River contain elevated levels of Pb, Hg, Zn, Cu. Cr. Cd, and Ni (Matusik, 1978; Malcom Pirnie, Inc. tMPI], 1975, 1978a; Tofflemire and Quinn, 1978; Tofflemire , 1984; Brown et al., 1988~. These heavy metals likely came from the Marathon Battery plant, the Hercules Chemical (now CIBA-Geigy) chemical plant, or other sources in the Hudson Falls -Glens Falls area (Tofflemire and Quinn, 1978; Tofflemire, 1984~. In general, large lead discharges from the Hercules plant occurred at the same time as PCB discharges from the GE plants. Thus sediments containing elevated PCB levels also tend to be high in lead. The details of the lead pollution of the upper Hudson River are not known and have not been carefully investigated. Measurements of heavy-metal content have been made in samples collected near Fort Edward Dam and in the remnant deposits (Table 1~. TABLE 1 Heavy-Metal Content of Selected Upriver Sediments Sample Metal Lead Cadmium Copper Mercury Arsenic Zinc Fort Edward Dam (brown fibrous 234 to 14 to 27 to 0.28 to 3 ~ 2 to 74 to sludge and 3630~8) 138~8) 159~8) 1. 28~4) 22 (8) 2950 (8) black silt) Remnant de- (ug/g) (ug/g) pos its Area 3A < 3 to 6 to 5600 110 Area 4 20 to < 4 to 480 12 Area 5 40 to < 4 to 1100 93 SOURCE: MPI, 1975, 1978a

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374 Cesium-137 Fallout Cesium-137 fallout from nuclear weapons tests carried out in the atmosphere during the 1950s has been used to indicate ages of sediment layers in core samples. A large network of cores in which cesium-137 has been used in this way has been established in the Hudson River by investigators from Lamont-Doherty Geological Observatory of Columbia University (Bopp, 1979; Bopp et al., 1978, 1981, 1982, 1984; Simpson et al., 1976, 1984~. ANTHROPOGENIC HISTORY The large-scale PCB pollution of the upper Hudson River can be resolved into two components: 1. introduction of PCBs into the river starting about 1950, and until 1973, the temporary storage of most of them in the first sediments they encountered, in the pool behind the Fort Edward Dam; and 2. wholesale spreading throughout the entire system as a result of two large floods in April 1974 and April 1976, after the dam had been removed in 1973 without any acknowledgment that the sediments stored behind the dam (now known as the remnant deposits) might contain elevated levels of PCBs nor of any sig- nificant consideration of the possible environmental conse- quences of post-dam-removal floods in eroding and spreading of these highly contaminated sediments downriver (MPI, 1975; 1977a, b; 1978b). PCBs were introduced into the upper Hudson River via daily dis- charges of plant cleanup water from two capacitor-manufacturing facili- ties of the General Electric Company (GE). GE began using PCBs at Hud- son Falls in 1947 and at Fort Edward in 1952 (Helling and Horn, 1977; Hetling et al., 1978~. In late 1972, the U.S. Congress passed the Water Pollution Control Act, which assigned responsibility for regulating the discharges of industrial wastes into waterways to the newly formed U.S. Environmental Protection Agency (EPA) via a program of permits. In December 1972, GE applied to EPA for a permit to discharge 30 to 47.6 pounds per day of PCBs into the upper Hudson River. In January 1975, EPA granted GE a permit to discharge 30 pounds per day of PCBs into the upper Hudson River and assigned monitoring of the permit to the New York State Department of Environmental Conserva- tion (NYS DEC). The first public announcement of high levels of PCBs in fish from the Hudson River came from concerned private citizens. Robert Boyle, of the Hudson River Fishermen's Association, persuaded editors at Sports It lustrated magazine to support a program of catching and sampling coastal game fish for pesticide residues, mercury, and PCBs. The results of the analyses (carried out by the WARP Laboratories, Madison, Wisconsin) were published in October, 1970 (Boyle, 1970~.

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375 In 1975, nearly five years later NYS DEC announced that fish containing levels of PCBs well above the FDA action level of five parts per million (ppm) were being caught in the Hudson River (Boyle, 1975~. The entire upper river fishery and the Hudson estuary commercial striped bass fishery were closed. An administrative proceeding was initiated against GE that sought cessation of PCB discharges, penalties from GE for having polluted the river, and rehabilitation of the upper river to mitigate the effects of the PCB contamination. A settlement was negotiated between NYS DEC and GE in which GE agreed to build wastewater-treatment facilities at its two capacitor- manufacturing plants, cease PCB discharges by July 1977, make a cash payment of $3 million to the state to study the extent of PCB pollution and/or carry out rehabilitation measures, and carry out $1 million worth of environmentally oriented in-house research. For its part, NYS DEC accepted the principle of joint culpability; agreed to put up $3 million in cash or in kind for studies and/or rehabilitation; to estab- lish an Advisory Committee of independent experts and representatives of several governmental agencies and the general public; and, should comprehensive study recommend large-scale rehabilitation, to use its best efforts to seek funds from sources "other than GE" to assist in rehabilitating the river (e.g., the federal government) (Sofaer, 1976a, b! The Hudson River PCB Settlement Advisory Committee established by the agreement assisted NYS DEC in all phases of the comprehensive studies. Members of its remnant deposits subcommittee brought remnant deposits to the forefront of the thinking about the river by NYS DEC staff. Prior to this time, NYS DEC's view regarding the remnant depo- sits was to let them be eroded from their riverbank locations in a steep-walled, inaccessible bedrock gorge and be redeposited at Fort Edward, where they became more accessible and thus could be removed at least cost (MPI, 1975~. The initial version of the 1976 contractor report that recommended strategies to be followed in the second cleanup of Fort Edward did not mention the PCB-pollution problem (MPI, 1977b). It even recommended disposing of the dredge spoil as usual by dumping it without treatment on Rogers Island. The PCB Settlement Advisory Committee rejected the contractor recommendation and insisted on encapsulation of the proposed dredge spoil and construction of a haul road down the east wall of the gorge containing the remnant deposits to give access to heavy construction vehicles; removal and encapsulation of the most highly contaminated sediments in Area 3A, an area so highly polluted with PCBs that no plants were growing; transport of quarried stone blocks to the site for riprap to prevent further bank erosion in the Area 3.

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390 Moreau facility. Accordingly, the only alternative other than dredging that has been considered is the no-action alternative. Doing nothing had been re- jected as a responsible way in which to deal with a toxic-waste prob- lem. However, the delays in obtaining permits for constructing the proposed containment site have allowed 10 years of no action to elapse. Basis for Rejecting Alternatives In its applications to Siting Boards I and II, the state of New York sought permission only for dredging and secure encapsulation. As noted, however, NYS DEC was directed to expand its permit application to include various PCB stripping and/or destruction technologies. For future reference, the Advisory Committee is evaluating the merits of the top three alternatives listed in the Carpenter report, and the Wright Malta process. The basis for making a final decision on a method of treating PCB- contaminated sediments to be dredged and placed in a secure encapsu- lation site using Sec. 116 funds has not been determined. As with many other projects, the decision probably will depend on financial consider- ations. If and when EPA re-evaluates its 1984 ROD in light of the terms of Superfund II, it will be obliged to reexamine previous decisions under Superfund I and to prefer destruction methods to encapsulation. EPA has not scheduled any activities under Superfund II. EPA Region II has raised the possibility of entering the upper Hudson River into the SITE program under SARA. Should that happen, the final decision about treating the contaminated sediments will be based on field trials on the scene. So far, among the candidate processes, only the Ozonic Tech- nology and Wright Malta (including Zurn et al.) processes are designed to destroy PCBs while or after stripping them from contaminated sedi- ments, and of these, only the Wright Malta process renders the heavy metals in the residue in nonteachable form. Of the stripping-only pro- cesses, only Resource Recovery Corporation's B.E.S.T. scheme using tri- ethylamine deals with both PCBs and heavy metals. Basis for Choosing a Remedial Action The position reached by NYS DEC and the Advisory Committee is that any rehabilitation of the upper Hudson River has to begin with dredg- ing. No in-river process is viable. Moreover, all available PCB recovery and/or destruction processes require that the sediment first be removed from the river. And in conformance with U.S. law, any sediment containing more than 50 ppm of PCBs that is removed from the river must be placed in a secure encapsulation facility. Thus, while both EPA and NYS DEC are moving away from so-called landfills as ways to deal with solid wastes, the law requires that a secure encapsulation facility be constructed, even if the site is to be used only for a work space for stripping PCBs from the sediments and/or destroying them.

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391 All of the final-treatment processes mentioned previously are avail- able only for processing contaminated sediments that have been dredged from the river. If that is to be done, a secure encapsulation facility must first be constructed. Anticipated Benefits A significant anticipated benefit of the proposed remedial dredging is to forestall further spread of PCBs into the lower reaches of the Hudson Rivers The proposed hot spot dredging in the Thompson Island pool would remove about 10 years' worth of PCB contamination at exist- ing rates of PCB flux over the Federal dam at Green Island. However, the main benefit of carrying out proposed hot spot dredging and secure encapsulation (and/or final cleanup) is that it may trigger EPA to re-examine its "interim measures" adopted in the July 1984 ROD under Superfund I. Under Superfund II, EPA is obligated to re-examine its previous determination about public-health effects. EPA has named GE as a "responsible and liable party" for the PCB pollution of the upper Hudson River. Although New York State has "signed off" with GE with respect to obtaining further funds to deal with the pollution, EPA has refused GE's offer to "cash out" with respect to Superfund by paying for the recommended interim treatment of the remnant deposits. Therefore, if NYS DEC succeeds in obtaining permits for the requested PCB-encapsulation site, EPA may re-examine its interim recommendation about disposition of the remnant deposits. Under Superfund I, EPA recommended only a temporary measure: covering the remnant deposits with 6 inches of clay. The Advisory Committee believes that removal and treatment of these deposits are the keys to rehabilitating the upper Hudson River. Currently, the proposed hot spot dredging is the key to the future ultimate removal and/or PCB destruction of the remnant deposits. Costs Since 1977, nearly $10 million has been spent on field work (includ- ing coring), mapping, PCB analyses, fish monitoring, and partial rehabi- litation of the upper Hudson River. This compares with a 1977 estimate prepared for GE's attorneys of $15 million just to prove the extent of PCB contamination in the sediments and as much as $250 million to clean up all contaminated sediments by dredging. IMPLEMENTATION/MONITORING In the upper Hudson River, many of what might be referred to as "remedial actions'' were taken before any toxic waste problems had been identified, indeed, before any toxic waste legislation had been passed. Moreover, to maintain a navigation channel to Fort Edward terminal, PCB-contaminated sediments have been dredged repeatedly out

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392 of the upper Hudson River near Fort Edward. Accordingly, records are available to show what has been dredged both before and after the pub- lic awareness of PCB contamination. In addition, NYS DEC's action against GE, which led to the 1976 Settlement Agreement, forced GE to cease PCB discharges and to take certain other steps. Remedial Action Taken Pursuant to the 1976 Settlement Agreement, GE took three signi- ficant actions in connection with PCBs in the upper Hudson River: 1. it stopped discharging PCBs into the river on July 1, 1977; it constructed wastewater treatment facilities at its capa- citor manufacturing plants at Fort Edward and Hudson Falls; and it is now using alternative compounds (alkyl pthalates) in its capacitors. NYS DOT Dredging DOT dredging operations included routine channel maintenance and two massive clean-up operations at Fort Edward as a result of surges of remnant deposits eroded by floods in the Hudson River in 1974 and 1976. NYS DEC Remnant Deposit Actions (1975-1978) NYS DEC erosion control measures (I). As armor against bank scour in Area 5 (Figure 11), 4,700 yd of stone purchased from a nearby quarry were used to construct riprap for 1,100 feet of riverbank at a cost of $75,000. In Area 2, the slope leading to the river along 2,800 ft of bank was graded and planted at a cost of $72,000. The 94 now exposed but former in-river cribs were dismantled and the rocks filling them placed along the riverbank for about 2,000 of the 3,100 ft of Area 3 shoreline and all along the shore of Area 4. NYS DEC erosion control measures (II). The April 1976 flood constituted a severe test of NYS DEC's erosion control measures (I). The rock riprap of Area 4 and 5 withstood the flood waters, but the slope grading and planting and partial rock treatment did not. After the recommendations from the Advisory Committee, NYS DOT built a haul road down the steep east valley wall enabling more stone to be hauled in. To prevent further scour, a complete rock riprap was built along the eastern shore of the river at Area 3. Area 3A sediments encapsulated at new Moreau facility. The most highly contaminated remnant deposits were found in Area 3A. 3As part of the rehabilitation program recommended to NYS DEC, 14,000 yd of debris were scraped from the barren flats in Area 3A and trucked to the new Moreau encapsulation facility.

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393 Monitoring of Remedial Actions All actions dealing with PCB pollution have been extensively moni- tored. The results of the USGS water-monitoring program are shown in Figure 12. Monitoring of fish has shown that the PCB values in fish caught has declined from its peak in the 1970s (Figure 13~. By 1980, values of PCBs in striped bass in the Hudson estuary fluctuated accor- ding to river discharge. When discharge increased, PCB values in striped bass increased, and vice versa. Other biomonitoring results are contained in Simpson et al. (19869. INSTITUTIONAL/MANAGEMENT CONSIDERATIONS New York State Constitutional Mandate re: Barge Canal The New York State Constitution, Article 15, Canals, prohibits the State from disposing of the canal system, in effect a constitutional mandate to maintain the barge-canal system. This article obliges indi- vidual legislatures to appropriate funds needed to keep the canal sys- tem operative, including maintenance dredging as required. In terms of PCB pollution, NYS DOT has in the past removed an estimated 160,000 lbs of PCBs in the sediments dredged (Tofflemire and Quinn, 1979~, and will have to continue to dredge to stay ahead of the accumulating sediment. Accordingly, the state will need to acquire one or more sites for the upland deposition of dredge spoils that will contain large concentra- tions of PCBs for the foreseeable future. The so-called no action alternative, therefore, only applies to dredging unrelated to channel maintenance. Miscellaneous Political Considerations No history of Hudson River PCB pollution would be complete without some mention of several political considerations--changing governors and NYS DEC commissioners, the relationships between New York State and GE, the opposition to the proposed encapsulation sites by nearby residents, Congressman Gerald B. Solomon's opposition, differences between upstate and downstate residents, organizational problems in state government, and the ambivalent attitudes of the citizens of Fort Edward, who favored beneficial dredging operations while opposing those related to rehabilitation. CONCLUDING REMARKS Although government action has been slowly moving toward rehabilita- tion of the upper Hudson River, the Hudson River has continued to trans- port PCBs into the estuary. As a result of the cessation in 1977 of GE discharges of PCBs, of remedial action taken with respect to the rem- nant deposits, and of less water flowing in the river, the amounts of

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394 2500 2000 o 1500 . _ c . _ J 1000 500 , 6 /// ~ . I\\' l 29 .l~ A Scouring \ \1 Nonscouring as O ~ Act. 1977 19 78 1979 1980 1981 t982 19133 1984 19615 1986 i FIGURE 12 Annual transport of PCBs in the Hudson River at Waterford. Numbers above the bars indicate the number of days with flow above the estimated scour threshold of 600 m /see (Barnes, 1987~. 160 140 120 100 PCB (PPM) 80 60 40 20 - - '1 ~ , T. $ . POOL STILLWATER ~ CATSKILL --am 1977 1978 1979 1980 19Bl 1982 1983 1984 YEAR FIGURE 13 PCBs in largemouth bass, 1977 to 1984.

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395 PCBs per year has dropped from about 2 tonnes in the late 1970s to 1 tonne and less in the 1980s. PCB values in fish showed a comparable decline until 1983. Since 1983, the PCB content of striped bass caught in the Hudson estuary has averaged about 4 ppm, but has fluctuated with river discharge. The 1980s values of PCBs in striped bass, are less than the pre-1984 FDA action limit of 5 ppm but more than the current action limit of 2 ppm. Upstate opponents of the proposed dredging proj ect are content with the no-action alternative. They consider that time is on their side. Moreover, if no remedial action is taken, the possibility exists that the PCB-contaminated sediments will wash away from their existing up- state locations and be transported downstate. If NYS DEC is able to carry out its proposed hot- spot dredging project, the earliest date for beginning work is probably 1993 or 1994. This ~ s about 20 years after the high-water flows at Ohm Arty and mid- 1970s . cycle exists, background of __ .~. _~. "~` And V1 "LIG ~J~V~ . `~1G ~V=~1~1 lity of doing the dredging proj ect during the low-flow decade of the 198~ has been ~c~~nnfl~r-d hot-spot dredging probably 1993 or of the early about 20 years after the high-water flows According to the disputed concept that a 20-year flow dredging done in the early l990s will be done against a flows much larger than those of the 1980s. The possib; the dredging project during the low-flow decade of the squandered. I consider it urgent to re-evaluate the EPA's ROD of July 1984. NYS DEC's attempt to establish an intellectual basis for the upriver PCB pollution situation does not include any effort to pressure EPA to carry out the terms of SARA and re-vis it its Superfund I conclusions. It is unlikely that NYS DEC can carry out any significant rehabilita- tion of the upper Hudson River unless EPA reverses its previous ROD and finds that the continuing downriver transport of PCBs constitutes a threat to human health. NYS DEC should develop a public-relations campaign setting forth its arguments in favor of the proposed rehabilitation measures that would compare favorably with the one of December 1984 that was orches- trated by GE on the subject of "biodegradation" of PCBs. If New York City continues to press for permission to augment its drinking water supply by tapping into the Hudson River, the human health impacts of PCBs in the Hudson River will be magnified many times. Only aroused public demand for ridding the Hudson River of PCBs is likely to stim- ulate public officials into taking significant actions. REFERENCES Armstrong, R. W. and R. J. Sloan. 1980. Trends in Levels of Several Known Chemical Contaminants in Fish from New York Waters. Tech- nical Report 80-2. Albany, New York: Department of Environmental Conservation. 77p. Armstrong, R. W. and R. J. Sloan. 1981. PCB patterns in Hudson River fish. I. Resident/freshwater species. Proceedings, Hudson River Environmental Society, Hyde Park, New York. Barnes, C. R. 1987. Polychlorinated biphenyl--transport in the upper Hudson River, New York, 1977-83. Northeastern Environ. Sci. 6~1~.

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396 Beeton, A. M., Chairman. 1979. Polychlorinated Biphenyls. Washington, D.C.: National Research Council. 182 p. Bopp, R. F. 1979. The Geochemistry of Polychlorinated Biphenyls in the Hudson River. New York: Columbia University, Department of Geological Sciences. Ph.D. dissertation. 191 p. Bopp, R. F., H. J. Simpson, B. L. Deck, and N. Kostyk. 1984, Persis- tence of PCB components in sediments of the lower Hudson. North- eastern Environ. Sci. 3~3/4~:180-184. Bopp , R. F., H. J . Simpson, and C. R. Olsen. 1978. PCB Analysis in the Sediments of the Lower Hudson. Palisades, New York: Lamont-Doherty Geological Observatory. 35 p. Bopp, R. F., H. J. Simpson, C. R. Olson, and N. Kostyk. 1981. Poly- chlorinated biphenyls in sediments of the tidal Hudson River, New York. Environ. Sci. Technol. 15~2~:210-216. Bopp, R. F., H. J. Simpson, C. R. Olsen, and N. Kostyk. 1982. Chlorin- ated hydrocarbons and radionuclide chronologies in sediments of the Hudson River and Estuary, New York. Environ. Sci. Technol. 16(10):666-676. Boyle, R. H. 1970. Poison roams our coastal seas. Sports Illustrated 33: 70-74. Oct. 16, 1970. Boyle, R. H. 1975. Of PCB ppms from GE and a SNAFU from EPA and DEC. Audubon 77~6~:127-133. Brown, J. F., R. E. Wagner, D. L. Bedard, M. M. Brennan, J. C. Carnahan, H. Feng, and R. E. Wagner. 1987. Polychlorinated biphenyl dechlorination in aquatic sediments. Science 236:709-712. Brown, J. F. Jr., R. E. Wagner, D. L. Bedard, H. J. Brennan, J. C. Carnahan, R. J. Mayh, and T. J. Tofflemire. 1984. PCB transform- ations in upper Hudson sediments. Northeastern Environ. Sci. 3~3/4~:167-179. Brown, M. P. and M. B. Werner. 1985. Distribution of PCBs in the Thompson Island Pool of the Hudson River, PCB Hot Spot Confirmation Report. Albany, New York: Department of Environmental Conservation. 34 p. Brown, M. P., B. Bush, G-Y. Rhee, and L. Shane. 1988. PCB dechlorina- tion in Hudson River sediments. Science 240: 1674-1675. Brown, M. P., M. B. Werner, C. R. Carusone, and M. Klein. 1988. Distri- bution of PCBs in the Thompson Island Pool of the Hudson River. Albany, New York: Department of Environmental Conservation. 94 p. Buckley, E. H. 1982. Accumulation of airborne polychlorinated biphenyls in foliage. Science 216: 520-522. Buckley, E. H. 1983. Decline of background PCB contamination in vegeta- tion in New York State. Northeastern Environ. Sci. 2:181-187. Buckley, E. H. 1987. PCBs in the atmosphere and their accumulation in foliage and crops. In Phytochemical Effects of Environmental Comkpounds, J. A. Saunders, L. Kosak-Channing, and E. E. Conn, eds. New York: Plenum Press. Pp. 175-201. Bush, B., L. A. Shane, M. Wahlen, and M. P. Brown. 1986. Sedimenta- tion of 74 PCB cogeners in the upper Hudson River. Chemosphere 16:733-744.

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397 Carpenter, B. H. 1987. PCB Sediment Decontamination Processes--Selec- tion for Test and Evaluation. Research Triangle Park, North Carolina: Research Triangle Institute. 173 p. Chen, M., C. S. Hong, B. Bush, and G-Y. Rhee. 1988. Anaerobic bio- degradation of polychlorinated biphenyls by bacteria from Hudson River sediments. Ecotoxicol. and Environ. Safety 16:915-105. Darmer, K. I. 1987. Overview of Hudson River Hydrology. New York: Hudson River Foundation for Science and Environmental Research, Inc. 174 p. Fairbridge, R. W. and J. E. Sanders. 1987. The Sun's orbit, A. D. 750- 2050: Basis for new perspectives on planetary dynamics and Earth- Moon linkage. Pp. 446-471. Friedman, G. M. and J. E. Sanders. 1978. Principles of sedimentology. New York: John Wiley and Sons. 792 p. Hetling, L. J. and E. G. Horn. 1977. Summary of Hudson River PCB Study Results. Albany, New York: Department of Environmental Conservation. 62 p. Hetling, L. J., E. G. Horn, and T. J. Tofflemire. 1978. Summary of Hud- son River PCB Study Results. Technical Paper 51. Albany, New York: Department of Environmental Conservation. 88 p. Landscheidt, T. 1987. Long-range forecasts of solar cycles and climate change. In Climate: History, Periodicity, and Predictability, M. R. Rampino, J. E. Sanders, W. S. Newman, and L. K. Konigsson, eds. New York City: Van Nostrand Reinhold. Pp. 421-445. Lawler, Matusky and Skelly, Engineers. 1978. Upper Hudson River No Action Alternative Study. Pearl River, New York: Department of Environmental Conservation. 190 p. Lawler, Matusky and Skelly, Engineers. 1979. Upper Hudson River PCB Transport Modeling Study. Pearl River, New York: Department of Environmental Conservation. Malcolm Pirnie, Inc. 1975. Investigation of Conditions Associated with the Removal of Fort Edward Dam, Fort Edward, New York. White Plains, New York: MPI. 118 p. Malcolm Pirnie, Inc. 1977a. Environmental Assessment of Maintenance Dredging at Fort Edward Terminal Channel, Champlain Canal. White Plains, New York: MPI. 271 p. Malcolm Pirnie, Inc. 1977b. Engineering Report, Investigation of Condi- tions Associated with the Removal of the Fort Edward dam, Fort Edward, New York. Review of 1975 Report. White Plains, New York: MPI. 141 p. Malcolm Pirnie, Inc. 1978a. Phase I Engineering Report--Dredging of PCB Contaminated Hot Spots, Upper Hudson River, New York. Albany, New York: Department of Environmental Conservation. 134 p. Malcolm Pirnie, Inc. 1978b. Feasibility Report, Dredging of PCB-Con- taminated River Bed Materials from the Upper Hudson River, New York. White Plains, New York: MPI. Malcolm Pirnie, Inc. 1978c. Environmental Assessment of Remedial Measures at the Remnant Deposits of the Former Fort Edward Pool, Fort Edward, New York. White Plains, New York: MPI. 173 p.

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398 Malcolm Pirnie, Inc. 1979. Removal and Encapsulation of PCB-Contamin- ated Hudson River Bed Materials. White Plains, New York: MPI. Malcolm Pirnie, Incq 1980a. Engineering report, PCB Hot Spot Dredging Program, Upper Hudson River: Containment Site Investigations. Program Report No. 1. White Plains, New York: MPI. Malcolm Pirnie, Inc. 1980b. PCB Hot Spot Dredging Program, Upper Hudson River: Dredging System Report. Program Report No. 2. White Plains, New York: MPI. Malcolm Pirnie, Inc. 1980c. Draft Environmental Impact Statement. New York State Environmental Quality Review: PCB hot spot Dredging Program, Upper Hudson River, New York. White Plains, New York: MPI. Malcolm Pirnie, Inc. 1981. Draft PCB Hot Spot Dredging Program, Upper Hudson River, New York: Rescoping Report. White Plains, New York: MPI. Matusik, J. J. 1978. Data on Heavy Metals in Hudson River Sediments. Albany, New York: Department of Health, Radiological Science Laboratory. Nadeau, R. J. and R. A. Davies. 1974. Investigation of Polychlorinated Biphenyls in the Hudson River: Hudson Falls-Fort Edward Area. New York City: EPA Region II. Nadeau, R. J. and R. A. Davies. 1976. Polychlorinated biphenyls in the Hudson River (Hudson Falls-Fort Edward, New York State). Bull. Environ. Contam. Toxicol. 16~4~:436-444. Nichols Engineering and Research Corporation. 1978. Decontamination of PCB-Laden Hudson River Bottom Sediment for General Electric in the 36 Inch Nichols/Herreshoff furnace. New Jersey. Normandeau Associates, Inc. 1977. Hudson River Survey 1976-1977 with Cross-Section and Planimetric Maps. Bedford, New Hampshire: Normandeau Associates. 351 p. NUS Corporation. 1983. Feasibility Study: Hudson River PCBs Site, New York. Pittsburgh, Pennsylvania: NUS Corporation. NUS Corporation. 1984. Draft Feasibility Study of Remedial Action Alter- natives. Acushnet River Estuary above Coggeshall Street Bridge, New Bedford site, Bristol County, Massachusetts. Pittsburgh, Pennsylvania: NUS Corporation. O'Brien and Gere, Engineers. 1978. PCB Analysis of Hudson River Sam- ples: Final Report. Syracuse, New York: O'Brien and Gere. 150 p. Robideau, J. A., P. M. Burke, and R. Lumia. 1984. Maximum Known Stages and Discharges of New York Streams through September 1983. Open-File Report 83-927. Reston, Virginia: U.S. Geological Survey. 83 p. Schroeder, R. A. and C. R. Barnes. 1983a. Polychlorinated Biphenyl Concentrations in Hudson River Water and Treated Drinking Water at Waterford, New York. USGS Water Resources Investigations, Report 83-4188. Reston, Virginia: U.S. Geological Survey. 13 p. Schroeder, R. A. and C. R. Barnes. 1983b. Trends in Polychlorinated Biphenyl Concentrations in Hudson River Water Five Years after Elimination of Point Sources. USGS Water Resources Investigations, Report 83-4206. Reston, Virginia: U.S. Geological Survey. 28 p.

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399 Simpson, H.J., R. F. Bopp, B. L. Deck, S. Warren, and N. Kostyk. 1984. Polychlorinated biphenyls in the Hudson River: The value of individual packed-column peak analysis. Northeastern Environ. Sci. 3~3/4~:159-165. Simpson, H. J., C. R. Olsen, R. M. Trier, and S. C. Williams. 1976. Man-made radionuclides and sedimentation in the Hudson River Estuary. Science 194:179-183. Simpson, K. W. 1986. Biomonitoring of PCBs in the Hudson River. I. Results of long-term monitoring using caddisfly (insecta: Trichoptera: Hydropsychidae~ larvae and multiplate residues, p. 1-68. II. Development of field protocol for monitoring PCB uptake by caged live Chironomus cantons (Insecta: Diptera: Chironomidae) larvae during dredging operations. Pp. 69-99. Sloan, R. J., M. P. Brown, and C. R. Barnes. 1984. Hudson River PCB relationships between resident fish, water and sediments . Northeastern Environ. Sci. 3~3/4~:148-152. Sloan, R.J., K. Simpson, R. A. Schroeder, and C. R. Barnes. 1983. Temporal trends toward stability of Hudson River PCB contamination. Bull. Environ. Contam. Toxicol. 31:377-385. Sloan, R. J., B. Young, V. Vecchio, K. McKown, and E. O'Connell. 1988. PCB Concentrations in the Striped Bass from the Marine District of New York State. Technical Report 88-1. Albany, New York: Department of Environmental Conservation. 23 p. Sofaer, A. D. 1976a. Interim opinion and order. Opinion in the matter of violations of the Environmental Conservation Law of the State of New York by General Electric Company. File No. 2822, 9 February 1976, Department of Environmental Conservation, Albany, New York. Sofaer, A. D. 1976b. Recommendation of settlement. Opinion in the matter of violations of ECL by General Electric Company, New York. File No. 2833, Department of Environmental Conservation, Albany, New York. Stone, W. B., E. Kiviat, and S. A. Butkas. 1980. Toxicants in snapping turtles. NY Fish and Game J. 27~1~:39-50. Texas Instruments Incorporated Ecological Services. 1976. A synthesis of available data pertaining to maj or physiochemical variables within the Hudson River Estuary emphasizing the period from 1972 through 1975. Prepared for Consolidated Edison Company of New York, Tnc. Tofflemire, T. J. and S. O. Quinn. 1979. PCB in the upper Hudson River: Mapping and sediment relationships. Technical Paper No. 56. Albany, New York: Department of Environmental Conservation. 144 p. Tofflemire, T. J., L. J. Hetline, and S. O. Quinn. 1979a. PCB in the Upper Hudson River: Sediment Distributions, Water Interactions and Dredging. Technical Paper No. 55. Albany, New York: Department of Environmental Conservation. 68 p. Tofflemire, T. J., S. O. Quinn, and P. R. Hague. 1979b. PCB in the Hudson River: Mapping, Sediment Sampling and Data Analysis. Technical Paper No. 57. Albany, New York: Department of Environmental Conservation. Turk, J. T. 1980. Applications of Hudson River basin PCB-transport studies. In Contaminants and Sediments, R. A. Baker, ed. Ann Arbor, Michigan: Ann Arbor Science Publications. Pp. 171-183.

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400 Turk, J. T. and D. W. Troutman. 1981a. Relationship of water quality of Hudson River, New York, during peak discharges to geologic characteristics of contributing subbasins. USGS Water-Resources Investigations 80-108. Reston, Virginia: U.S. Geological Survey. 15 Pe Turk, J. T. and D. W. Troutman. 1981b. Polychlorinated Biphenyl Trans- port in the Hudson River, New York. USGS Water-Resources Investiga- tions 81-9. Reston, Virginia: U.S. Geological Survey. 11 p. U.S. Geological Survey. 1974-1987. Water Resources Data for New York. Albany, New York, Water-Data Reports. Volume 1, Eastern New York Excluding Long Island. Issued annually. Reston, Virgina: U.S. Geological Survey. Werner, M. B. 1981. The Use of a Freshwater Mollusc (El l iptio compla- planatus) in Biological Monitoring Programs. B. The Freshwater Mussel as a Biological Monitor of PUB Concentrations in the Hudson River. Albany, New York: Department of Environmental Conservation. Weston Environmental Consultants. 1978. Migration of PCBs from Land- fills and Dredge Spoil Sites in the Hudson River Valley, New York. West Chester, Pennsylvania: Weston Environmental Consultants. Wood, F. J. 1978. The Strategic Role of Perigean Spring T6des in Nauti- cal History and North American Coastal Flooding, 1635-1976. Washington, D.C.: NOAA. 538 p.