Hayworth N To Enck 2012 04 09 - US EPA
From:To:Date:Subject:Robert Michaels bam@ramtrac.com Larisa Romanowski/R2/USEPA/US@EPA05/04/2012 11:12 AMIssues for EPA to consider in its five-year review of Hudson River PCB dredgingIn its five-year review of the Hudson River PCB dredging project, EPA should consider the followingthree emerging developments in deciding whether Phase 2 can be resumed and implemented safely:--1. High-flow events are predicted to occur with increasing frequency in future years, as illustrated lastyear by events such as Tropical Storms Irene and Lee; such events will drive PCB sediments mobilizedby dredging downstream for decades to come;-–2. The US Commerce Department this year added sturgeon to the Endangered Species List, requiringprotection of their Lower Hudson River habitat from PCBs because, according to EPA (and others),their early life stages are unusually susceptible to PCBs, and-–3. Scientific articles now link PCBs to developmental processes that are thought to underlie causationof autism, most notably calcium channel effects that alter nerve cell dendrite branching patterns and, inturn, alter synapse formation in developing brains (in animal bioassays).EPA has used reported adverse effects of PCBs as justification for removing PCB-contaminatedsediments via dredging, but this is misleading for three reasons. First, fundamental to EPA’s dredgingplan is allowance of an increase in PCB mobilization for seven or so years of dredging on the hope thatreduction will be on the horizon. However, the horizon, as always, keeps receding as it isapproached. Second, natural attenuation is occurring and will continue to occur even withoutdredging. Third, cleaner methods of dredging can be used in place of clamshell dredging.EPA, therefore, must decide whether and how it can justify increased exposure to PCBs associatedspecifically with clamshell dredging for most of the next decade, and I would say well beyond. EPAfurther must explicitly address the newly recognized and increased risks to human and environmentalhealth, which already have materialized, and which will get worse before they get better as long asclamshell dredging continues for removal of PCB sediments in the Upper Hudson River.Additional and related issues for the five-year review are explicated in my letter, attached, published inthe Daily Gazette on 2012.04.28 and on my blog, at http://environmentalhealthrisk.blogspot.com. I lookforward to EPA's thorough, fair, and objective consideration of the issues explicated for the five-yearreview.I thank you for considering the facts that I have presented.Very truly yours,Bob MichaelsDr. Robert A. Michaels; PhD, CEPPresidentRAM TRAC Corporation3100 Rosendale RoadSchenectady, NY alhealthrisk.blogspot.combam@ramtrac.com(518) 785-0976
Daily Gazette Letters to the Editor for April 28Saturday, April 28, 2012Expansion of PCB dredging will only make Hudson dirtierEnvironmental groups advocating expansion of Hudson River PCB dredging (March 31 Gazette) arepremature at best, given the ongoing five-year review of the dredging project by the EnvironmentalProtection Agency.Maybe politics will drive the result of this review, but EPA and environmental groups should considerthe documented, substantial long-term consequences of dredging, rather than seizing on the simplistic,short-term expedient of digging up more PCB sediment. As past toxicologist for the Natural ResourcesDefense Council, I know that taking the long view is a hallmark of environmental activism.After the first season of dredging, GE reported that sediment samples outside the dredged area “showthat dredging caused widespread redistribution of PCB-containing sediments on the surface of the riverbottom.” High-flow events already have driven some of this dredge-mobilized sediment downstream.Future high-flow events likewise will transport dredge-mobilized PCBs downstream, where they willenter water, air and ecosystems. This includes the habitat of Hudson River sturgeon, recently classifiedas “endangered” by the Commerce Department, which now must protect its habitat under theEndangered Species Act.Maybe advocates of expanded dredging think EPA data indicate that dredge-mobilized PCBs are not aproblem, but this is false. EPA’s official Hudson River PCB Dredging Peer Review Panel concluded in2010 that the agency failed to set an allowable sediment loading limit, failed to gather data needed dothis, and failed to develop models to predict transport of dredge-mobilized sediment.The agency therefore cannot assure the public that transport of sediment already mobilized by dredgingwon’t increase for decades, threatening ecosystems in the Lower Hudson River. It cannot assure theCommerce Department that endangered sturgeon can survive decades of increased PCB transport to theLower Hudson River. Yet, the agency seeks to resume dredging.Phase 1 dredging was supposed to demonstrate the feasibility of Phase 2, but it did not do so. It wasdesigned to succeed because it featured bank-to-bank dredging to reduce mobilization of PCB sediments.Even so, massive sediment mobilization occurred. More will occur in Phase 2, because only PCB“hotspots’” will be dredged. Mobilization will transport PCBs to areas of the river bottom that are notslated for future dredging.High-flow events such as storms are forecast to occur with increasing frequency in the future. Futureevents will have more severe consequences, as the area of dredged river bottom increases. Cumulativetransport of dredge-mobilized PCB sediments may, [over time, stop] the recovery of endangered LowerHudson sturgeon.EPA should address these issues in its five-year review. Certainly, the Commerce Department will.Environmental groups likewise should consider them, to protect Hudson River communities andecosystems. To be an environmental activist is to take the long view. Environmental groups can ignorelong-term consequences of positions that they advocate for short-term benefit — but only at the peril oftheir legacies.Robert A. Michaels, PhDSchenectadyThe writer is president and principal toxicologist of RAM TRAC Corp.
Hudson River Sloop ClearwaterNatural Resources Defense CouncilRiverkeeperScenic HudsonMay 29, 2012Judith Enck, Regional AdministratorUS EPA Region 2294 BroadwayNew York, NYDear Judith:We are writing to urge USEPA to include and evaluate in the 5-Year Review of theHudson River PCB Superfund site all key unresolved concerns and issues raised by local,state and federal agencies involved in the Hudson River cleanup, including NYSDEC, the1 6 WWRUQH\ *HQHUDO¶V RIILFH the NYS Canal Corporation, NOAA, and USFWS, aswell as WKH &RPPXQLW\ GYLVRU\ *URXS¶V LQGHSHQGHQW WHFKQLFDO FRQVXOWDQWV and (3 ¶V own Phase 1 Peer Review Panel.We appreciate the time you and your staff have taken to meet with us in recent weeks.However, we remain gravely concerned that critical issues will not be substantiallyaddressed by the 5-Year Review that is currently slated for release by May 31, 2012.Specifically, given 86(3 ¶V GXW\ WR GHWHUPLQH WKH ³protectiveness RI WKH UHPHG\ DV LW LV currently being implemented, DQG WKH RYHUDOO FULWHULD DQG VWDQGDUGV RI WKH 86(3 ¶V Comprehensive Five-Year Review Guidance, the following topics that have been raisedby the above-referenced parties and that were described in our letter to you dated May4, 2012 must be afforded comprehensive treatment in the Review:xData collected since EPA issued the 2002 Record of Decision (ROD) show higherlevels of surface sediment contamination than the ROD anticipated in portions ofRiver Sections 2 & 3 that are not slated for dredging. These residuals raisesignificant scientific uncertainty as to whether all Remedial Action Objectives(RAOs), including target PCB levels in fish, will be fully achieved.xMonitoring of pre-and post-remedy sediment PCB concentrations is not adequateto determine the protectiveness of the remedy, especially in River Sections 2 & 3,where analyses of post-ROD data indicate that post-remediation PCBconcentrations will be five times higher than predicted by the ROD.xSediment and bioaccumulation models (HUDTOX and FISHRAND) used in theROD are no longer considered scientifically valid and require re-examination, inlight of the above-referenced data, to determine the likelihood that RAOs will befully achieved. (Post-Phase 1 modeling by GE validates WKH 52'¶V FRQFOXVLRQV
that dredging of contaminated sediment does not impede recovery of the riverthrough resuspension of PCBs, but rather achieves significant progress towardsRAOs by removing PCBs from the system. However, neither this model nor anyother updated sediment transport or bioaccumulation model has been used, todate, to evaluate whether higher-than-expected surface sediment PCBconcentrations outside of the area targeted for dredging will detract from theprotectiveness of the remedy.)xCurrent and projected changes in the physical site conditions, due to multipleflooding events, sediment re-deposition, and changing climate conditions, requirere-verification of sediment transport predictions (e.g., regarding areas notcurrently slated for dredging) and engineering standards for caps and habitatreconstruction.xInstitutional controls appear inadequate to prevent overexposure during theremedy and beyond (e.g., fish advisories are not preventing subsistence anglersfrom eating the fish).xDesign and standards for habitat reconstruction and species recovery are notoptimized and require improvements.We remain alarmed that the abbreviated deadline of May 31st will simply not allow allWKH FULWLFDO FRPSRQHQWV RXWOLQHG LQ 86(3 ¶V &RPSUHKHQVLYH )LYH-Year ReviewGuidance documents including identification of information that may warrantadditional studies to be completed in the rigorous manner they deserve.Moreover, since we understand that EPA has not received or invited comments from theNatural Resource Trustee agencies on the 5-Year Review, we are attaching to this letter,for inclusion in the record of the 5-Year Review, past correspondence and analysis by thefederal Trustees on several of the issues listed above.1Restoring the environmental and economic health of our world-renowned river dependson a rigorous implementation of the dredging remedy. The remedy must be responsive tothe most current information, practices and design standards to maximize the likelihoodof success. In light of the decades-long damages to this public resource, the interest ofdiverse stakeholders in a comprehensive restoration, and the enormous expense of thisremedy, EPA must openly and thoroughly examine the issues above and ensure anefficient, effective cleanup of the Hudson River.Certain documents publicly available at the following n/pdf/HUD DEL SETAC esign signed.pdfFederal Trustees' NRDA pre-meeting presentation to the Hudson River PCBs Superfund SiteCommunity Advisory Group on June 30, 2011:1
:H JUHDWO\ DSSUHFLDWH (3 ¶V FRPPLWPHQW over the last several years to a transparentpublic process during the implementation of this historic environmental project. And asalways, we will continue to share with you our concerns and hopes for the future of ahealthier Hudson River.Sincerely,Ned Sullivan, PresidentScenic HudsonPaul Gallay, PresidentRiverkeeperJeff Rumpf, PresidentHudson River Sloop ClearwaterLarry Levine, Senior AttorneyNatural Resources Defense CouncilCc:Admin. Lisa Jackson (EPA)Hudson Valley Congressional DelegationDeputy Sec. Energy & Envir. Bob Hallman (NYS Office of Governor)Asst. Dep. Sec. Envir. Basil Seggos (NYS Office of Governor)Asst. Admin. Mathy Stanislaus (EPA)Asst. Admin. Cynthia Giles (EPA)Cmr. Joe Martens (DEC)Dir. Brian Stratton (NYS Canal Corp)Asst. Cmr. Eugene Leff (DEC)Eric Schniederman (NY AG)Brian Donohue (DOJ)Wendi Weber (USFWS)Robert Foley (USFWS)Robert Haddad (NOAA)Tom Brosnan (NOAA)
Hudson River Remedy Part I:AbstractUnremediated PCBs and the Implications for RestorationThe Hudson River PCB Superfund Site encompasses approximately 200 milesfrom Hudson Falls to the Battery in New York City. The dredging remedy, se-Jay Field 1, Lisa Rosman 2, Tom Brosnan 3, Bob Foley 4lected in 2002, was estimated to remove 2.65 million cubic yards of sedimentsTable 3. Estimated number of acres and post-remedial surface Tri PCB concentrations based onadditional removal of cores outside of the current Phase 2 dredge prisms exceeding the RiverSection 1 surface criterion.1NOAA/OR&R/Assessment and Restoration Division: Seattle, Washington, USAfrom the upper 40 miles (River Sections 1, 2 and 3) between Fort Edward and2the Federal Dam in Troy. Characterization of sediment during remedial designfound higher and more widespread PCB concentrations in the surface, andTotal Number ofAcres OutsideRiverDredge Prisms withSectionSurface Tri PCB 10 ppmCoresAllwithinCores200 ft of OutsideDredge DredgePrismPrismNOAA/OR&R/Assessment and Restoration Division: New York City, New York, USA3NOAA/OR&R/Assessment and Restoration Division: Silver Spring, Maryland, USAmuch slower natural recovery than models predicted for the 2002 remedy. Thefirst phase of the remediation dredged 48.3 acres of River Section 1 in 2009and capping was required for about 36% of the dredged area. Phase 2 reme-Table 1. Target cleanup levels for the Upper Hudson River (EPA 2002).diation will commence in 2011 in River Section 1. Phase 1 and Phase 2 combined will remediate at least 493 acres and remove 95% or more of PCBs fromRiver Section 2River Section 1 (Reach 8: Thompson Island Pool):within that footprint. However, 136 acres of surface PCBs exceeding 10 ppmTable 2. Estimated capture efficiency of cores with surface concentrations greater than 10 ppm Tri PCBs by River Section based on Phase1 (GE 2005) and Phase 2 (GE 2007) dredge prisms. Capture efficiencyis calculated as the number of cores with surface concentrationexceeding 10 ppm Tri PCB removed divided by the total number ofcores with surface concentration exceeding 10 ppm Tri PCB.3 g/m2 Tri PCBs1 Mass per unit area (MPA)Tri (25-30 ppm total) PCBs will remain outside of the dredge footprint, and the10 mg/kg Tri PCBs in surface sediment (in top 12 inches)Fort Miller Poolaverage PCB concentration in the surface of River Sections 2 and 3 will be fiveNorthumberland Pooltimes higher after remediation than predicted by the 2002 remedy. Our analy-( 25-30 ppm total PCBs)ses evaluate the degree and extent of contamination remaining outside theRiver Sections 2 & 3 (Reaches 1-7)areas designated for dredging and the potential for impacts of the current10 g/m2 Tri PCBs MPACoreswithin200 ft ofDredgePrismAll .51.66.4RS362913.21.96.4Note: Basis for the acreage estimate: one core 1/8 acre from E. Garvey personal communication 2010. SurfacePCB concentrations as defined by EPA (2004).Capture Efficiency of Coreswith Surface Tri PCBs 10 ppmRemoval ofRiverCurrent DredgeAdditional CoresSection Area DelineationWithin 200 feet10.970.9920.640.9430.450.8430 mg/kg Tri PCBs in surface sediment ( 60-90 ppm total PCBs)remedy on recovery and restoration of the Hudson River.Estimated Tri PCB (ppm) inSurface Following AdditionalRemoval of Cores with SurfaceTri PCB 10 ppmHot Spot 361Tri PCBs: sum of trichloro- through decachlorobiphenyl PCBsHot Spot 37Fort Miller Pool (river reach 7) inthe vicinity of Thompson Island.IntroductionImpacts on Recovery andRestorationRemedial design sampling in the Upper Hudson (Figure 1) found higher and more widespread PCB concentration in the sur-Resultsface and much slower natural recovery than models predicted for the 2002 remedy.Average post-remediation surface sediment concentrations will be five times higher in River Section (RS)2 and RS3 thanFigure 1. The Upper Hudson River (UHR) section, subsection and reach designations.EPA anticipated when developing the ROD (Field et al 2009).Average surface PCB concentrations pre-remediation in RS1 andFigure 4. Map of the Upper Fort Miller Pool (River Section 2, river mile 187-8)showing cores outside of Phase 2 dredge prisms that exceed 10 ppm Tri PCB (redcircles) and are within 200 feet of dredge prism boundary (red circles with whitehalo).RS2 are comparable and exceed 100 ppm total PCBs (Figure 2).In December 2010, GE agreed to perform the second phase of dredging in the Upper Hudson River. According to EPA,“Phase two will require GE to remove an estimated 95 percent or more of PCBs from the areas designated for dredging.”The cleanup levels for RS2 and RS3 are three times higher than(EPA 2010).for RS1 (Table 1). As a result, estimated post-remediation surfaceRiver Section 3cent to planned dredge areas. This will result in the high likelihood of remedi-MethodsSurface sediment concentrations represent the concentration in the top 12 inches (EPA 2004).Calculation of average concentrations by river section before dredging: Most remedial design data (NOAA 2010) were collected using a systematic grid design. River section average sediment PCB concentrations were calculated as the arithmetic average of surface sediment concentrations (n 8884). For River Sections 2 and 3, most of the cores were collected from fine-grained sediments.1401401201201001008080ated areas becoming recontaminated.Many of the RS2 and RS3 cores with concentrations exceeding"QQSPQSJBUF SFTUPSBUJPO PG JOKVSFE OBUVSBM SFTPVSDFT VOEFS UIF /BUVSBM 3FTPVSDF the surface criterion for RS1 (10 ppm Tri PCB) are within 200t 8IBU BSF UIF QPUFOUJBM JNQBDUT PG UIFTF VOSFNFEJBUFE 1 #T PO SFTUPSBUJPO BOE SFDPWFSZ PG UIF SJWFS Tri and Total PCBs (mg/kg) t 8IBU XJMM SFNBJO JO UIF TVSGBDF TFEJNFOU PVUTJEF PG BSFBT EFTJHOBUFE GPS ESFEHJOHDamage Assessment (NRDA) process, should take place where those resourcesfeet of the Phase 2 areas designated for dredging (Figures 4-7).were most impacted. The magnitude of contamination remaining post - dredgingUsing the surface criterion for RS1 throughout the Upper HudsonMJLFMZ XJMM NBLF UIJT JOGFBTJCMF BOE SFTUPSBUJPO QSPKFDUT NBZ OFFE UP CF MPDBUFE would result in comparable surface concentrations (Figure 3) andGVSUIFS GSPN UIF TJUF PG JOKVSZ capture efficiencies in all three river sections (Table 2). Applying60604040202000ticipated in the 2002 ROD due to elevated PCBs remaining in the surface sedi-5IF NBKPSJUZ PG UIF FMFWBUFE QPTU DPOTUSVDUJPO TFEJNFOU DPODFOUSBUJPOT BSF BEKB-much in RS2 and RS3 (Figure 3). Recovery of the Upper and Lower Hudson River will be delayed longer than anment – equivalent to a series of Superfund-caliber sites being left behind.PCB concentrations will be greatly reduced in RS1, but not asThe focus of this presentation:Figure 5. Map of the Northumberland Pool (River Section 2, river mile 184)showing cores outside of Phase 2 dredge prisms that exceed 10 ppm Tri PCB (red circles) and are within 200 feet of dredge prism boundary (redcircles with white halo).Restoration of the Hudson could be significantly accelerated through additionalthe surface criterion for RS1in RS2 and RS3 would require dredg-SFNFEJBUJPO PG IJHIMZ DPOUBNJOBUFE TVSGBDF TFEJNFOUT BEKBDFOU UP DVSSFOUMZ EF-ing approximately an additional 136 acres (Table 3).lineated dredge areas. Failure to remediate those sediments will eliminate sig-Yellow floating heart, Nymphoidespeltata, at Hot Spot 36.nificant opportunities for restoration of natural resources in precisely those locations where it would be most valuable.12315151010River Sectionrespectively, and averages for each river section were re-calculated.Total PCBsFigure 2. Pre-dredging average Tri and Total PCB concentrations(mg/kg) in surface sediment by river section. Target cleanup levelfor surface is 10 mg/kg Tri PCB in River Section 1 and 30 mg/kgTri PCB in River Sections 2 and 3.Total PCBs (mg/kg)(GE 2005, GE 2007) were assigned surface sediment Tri PCB and total PCB concentrations of 0.25 ppm and 0.5 ppm,Tri PCBsTri PCBs (mg/kg)Calculation of estimated post-dredging PCB average concentrations: Cores within the remedial design dredge footprints5Figure 6. Map of area in the vicinity of Hot Spot 36 (River Section 3, river mile 170)showing cores outside of Phase 2 dredge prisms that exceed 10 ppm Tri PCB (redcircles) and are within 200 feet of dredge prism boundary (red circles with white halo).5Figure 7. Map of area in the vicinity of Hot Spot 37 (River Section 3, rivermile 166) showing cores outside of Phase 2 dredge prisms that exceed 10ppm Tri PCB (red circles) and are within 200 feet of dredge prism boundary(red circles with white halo).Referencest &1" 3FDPSE PG %FDJTJPO )VETPO 3JWFS 1 #T 4JUF /FX :PSL 6 4 &OWJSPONFOUBM 1SPUFDUJPO "HFODZ 'FCSVBSZ t &1" 'JOBM %FDJTJPO 3FHBSEJOH (FOFSBM &MFDUSJD PNQBOZ T %JTQVUFT PO %SBGU 1IBTF %SFEHF "SFB %FMJOFBUJPO 3FQPSU BOE %SBGU 1IBTF 5BSHFU "SFB *EFOUJmDB 0tion Report. July 26, 2004, Attachment 2.012River Section31NONE23River Section200 ftALLt &1" i&1" "OOPVODFT 3FRVJSFNFOUT GPS /FYU 1IBTF PG )VETPO 3JWFS 1 # MFBOVQ w 6 4 &OWJSPONFOUBM 1SPUFDUJPO "HFODZ %FDFNCFS t 'JFME ,FSO BOE - 3PTNBO i&WBMVBUJPO PG /BUVSBM 3FDPWFSZ .PEFMT GPS 4FEJNFOU JO UIF 6QQFS )VETPO 3JWFS w 1PTUFS 1SFTFOUBUJPO #BUUFMMF UI Interntional Conference on Remediation of Contaminated Sediments, February 2009, Jacksonville, Battelle09 Field NatRecovery 508.pdft (& 1IBTF *OUFSNFEJBUF %FTJHO 3FQPSU )VETPO 3JWFS 1 #T 4VQFSGVOE 4JUF 1SFQBSFE CZ ##- GPS (FOFSBM &MFDUSJD "MCBOZ /FX :PSL "VHVTU Figure 3. Post-dredging estimated average Tri and Total PCB concentrations (mg/kg) in surface sediment by riversection under three scenarios: 1) current remedial design; 2) additional removal of cores with surface Tri concentration exceeding 10 ppm that are within 200 feet of existing dredge areas; 3) additional removal of all cores with surfaceTri PCB concentration exceeding 10 ppm.t (& )VETPO 3JWFS 1 #T 4JUF 1IBTF %SFEHF "SFB %FMJOFBUJPO 3FQPSU 1SFQBSFE CZ 2VBOUJUBUJWF &OWJSPONFOUBM "OBMZTJT 2&" GPS (FOFSBM &MFDUSJD "MCBOZ NewYork. December 17, 2007.t /0"" )VETPO 3JWFS %BUBCBTF BOE .BQQJOH 1SPKFDU IUUQ SFTQPOTF SFTUPSBUJPO OPBB HPW RVFSZNBOBHFS
HUDSON RIVER NATURAL RESOURCEDAMAGE ASSESSMENT (NRDA)Pre-CAG Meeting, Ft. Edward, NYJune 30, 2011Tom Brosnan1, Bob Foley21. NOAA2. US Fish and Wildlife Service
Introduction on Trustee PerspectivesSuperfund –hazardous waste releases cleanup (EPA, NYSDEC): reduce or eliminate present andfuture threats to human health and/or the environment restoration (trustees: USFWS, NOAA, NYSDEC): protect andrestore injured natural resources; NRDA: past, present andfuture injuries/lost uses from release and remedyCoordination of cleanup and restoration -broad trustee goals: Minimize remaining surface contamination, and Maximize amount and quality of reconstructed habitatWhy? Most effective restoration and recovery begins withcleanup and reconstruction of habitats
Today:Presentations: analyses and recommendations to GE onimprovements to the Phase 2 Remedial Design thatcould be implemented to reduce ongoing and remedialinjury to natural resources and accelerate recovery ofthe river.1. Unremediated PCBS in the Hudson River:Implications for Recovery and Restoration2. Habitat Replacement and Reconstruction and theImplications for Restoration3. Q&A
Websites for Additional oaa.gov/northeast/hudson/admin.htmlTrustees Letter to GE on the Phase 2 Design df/lettertoGEPhase2designsigned.pdf. June 21, 2011Poster: Unremediated PCBS in the Hudson River: Implications for Recovery andRestoration . April f/HUD DEL SETAC 2011PCBposter.pdfPoster: Habitat Replacement and Reconstruction and the Implications forRestoration . April f/HUD DEL SETAC 2011habitatposter.pdf.
Websites (cont.)Poster: Evaluation of Natural Recovery Models for Sediment in the Upper Hudson River. udson/pdf/Battelle09 Field NatRecovery 508.pdfPoster: Estimated Post-Remedial PCB Concentrations in Especially Sensitive or Unique Habitats ofthe Upper Hudson River, February f/Battelle09 Rosman ESUH.pdfPoster: Especially Sensitive or Unique Habitats of the Upper Hudson River, November f/ESUHSETAC%20poster small.pdfTrustees Letter to General Electric regarding Phase 1 Final Design Report, August 14, f/final GE letter August 2006.pdfTrustees Letter to General Electric regarding Intermediate Design Report, November 7, f/letter GE November 2005.pdf
UNREMEDIATED PCBS IN THEHUDSON RIVER: IMPLICATIONS FORRECOVERY AND RESTORATIONJay Field1, Lisa Rosman1, Tom Brosnan1, Bob Foley21. NOAA/OR&R/Assessment and Restoration Division2. US Fish and Wildlife Service
Unremediated PCBs: SummaryPhase 2 remediation requires GE to remove at least 95% ofPCBs from the areas designated for dredging.Pre-dredging PCB concentrations in the Upper Hudson Riverare much higher than the levels predicted by the EPA’s models.Post-dredging, high levels of PCBs will remain in the surface inareas not designated for dredging, especially in River Section2 and 3 ---these are unremediated PCBs.Most of the unremediated PCBs are found in close proximity(within 200 ft) of existing dredge area boundariesUnremediated PCBs are likely to negatively impact therecovery and restoration of the river.
Key QuestionsModel Predictions: How do PCB concentrations in the surfacecompare with the PCB concentrations predicted by a model?(both before and after dredging)Extent of Unremediated PCBs: What are the expected PCBconcentrations in the surface sediment outside areasdesignated for dredging?Impacts of Unremediated PCBs: What are the potentialimpacts of these high levels of unremediated PCBs in surfacesediment on the recovery and restoration of the river?
Model Predictions: Pre-Dredging Surface SedimentConcentrationsEPA (and GE) used models to predict the PCB concentrations inthe surface sediment at the time of dredging (dredging wasexpected to begin in 2003) and after dredging wascompleted.Between 2002 and 2007, GE collected about 9000 sedimentcores to define areas that needed to be dredged according tothe selected remedial alternative in the ROD.
Model Predictions for 2003 Average SurfaceTri PCBs by River Section (top 5 cm)River Section1 Thompson Island Pool2 Schuylerville3A Stillwater3B Waterford3C Federal Dam Models evaluated cohesive(fine-grained) and noncohesive sediments. Model predictions of Tri PCBconcentrations in the surface byriver section and sediment typebefore the start of dredging. Samples collected to definedredge areas in River Sections2 and 3 targeted fine-grainedsediment (cohesive sediment).FS 2003 Cohesive Upper BoundFS 2003 CohesiveFS 2003 Non-Cohesive
Comparison of Average Tri PCBs by River Section fromRemedial Design with Model Predictions for 2003 Surface (top5 cm) Natural recovery models greatlyoverestimated the rate ofrecovery. Remedial Design Tri PCBconcentrations from the top 5 cm(red bars) exceeded the upperbound of model predictions (bluebars) and were more than 2X theconcentration predicted forcohesive sediments in all 3 riversections (green bars).Remedial Design Data 2002-07FS 2003 Cohesive Upper BoundFS 2003 CohesiveFS 2003 Non-Cohesive Widespread burial of PCBs in thesurface sediment was notobserved.
Estimated Post-Dredging Surface Concentrations fromModel Predictions The Record of Decisionexpected that the selectedalternative would result inaverage Tri PCBconcentrations in the upper 5 cmin cohesive sediments less than 1ppm throughout the UpperHudson.FS Post-Remedial CohesiveFS Post-Remedial Non-Cohesive
Estimated Post-Dredging Surface ConcentrationsCompared to Remedy Expectations River Section 1:Estimated post-dredging Tri PCB concentrations fromRemedial Design data for thetop 5 cm (red bars) arecomparable to modelpredictions River Sections 2 and 3:Post-dredging concentrationsare estimated to be about 5Xhigher than model predictionsRemedial Design Post-DredgingFS Post-Remedial CohesiveFS Post-Remedial Non-Cohesive
Unremediated PCBs: Surface“Surface” for the purposes of the targetcleanup triggers is defined by EPA as theconcentration of the PCBs in the top 12 inchesof sediment
Target Cleanup TriggersRiver Section 1 (Thompson Island Pool): 3 g/m2 Tri PCBs Mass per unit area (MPA) 10 mg/kg Tri PCBs in surface sediment (in top 12 inches)( 25-30 ppm total PCBs)River Sections 2 & 3 10 g/m2 Tri PCBs MPA 30 mg/kg Tri PCBs in surface sediment( 60-90 ppm total PCBs)
Pre-Dredging Surface PCBs140Tri and Total PCBs (mg/kg)140120120100100808060604040202000123River SectionTri PCBsTotal PCBsPrior to dredging: Average PCB concentrationsin the surface (top 12inches) in River Sections 1and 2 exceed 100 ppmtotal PCBs (solid blue bars)and 30 ppm Tri PCBs(hatched blue bars).
Estimated Post-Dredging Surface PCBs2020Tri and Total PCBs (mg/kg)Post-dredging:151510105500123River SectionTri PCBsTotal PCBs Surface PCB concentrationin River Section 1 will begreatly reduced. Surface PCB concentrationin River Sections 2 and 3,though reduced, will remainhighly elevated
River Section 2Upper Fort Miller PoolNorthumberland PoolRed circles with white haloexceed 10 ppm Tri PCB inthe surface and are within 200feet of existing dredge prismboundary
River Section 3Hot Spot 36Ho
Jay Field 1, Lisa Rosman 2, Tom Brosnan 3, Bob Foley 4from Hudson Falls to the Battery in New York City. The dredging remedy, se- The dredging remedy, se- 1 NOAA/OR&R/Asse
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