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Contaminated Marine Sediments: Assessment and Remediation (1989)

Chapter: PCB Pollution in the Upper Hudson River

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Suggested Citation:"PCB Pollution in the Upper Hudson River." National Research Council. 1989. Contaminated Marine Sediments: Assessment and Remediation. Washington, DC: The National Academies Press. doi: 10.17226/1412.
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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

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

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.

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 Cr—n labor ma—n ~~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.

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

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.

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

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~.

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

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~.

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.

376 The committee also recommended removal and encapsulation and/or final treatment of the remaining remnant deposits 3A be given the highest priority. The proposed Hudson River PCB reclamation-demonstration project had to be scaled down to fit with budget constraints, however, and the remnant deposits were dropped from the work plan, which concentrated exclusively on removal of PCB-contaminated "hot spots" in the Thompson Island Pool. The committee unanimously recommended to Commissioner in June 1978 that the only feasible means for rehabilita- ting the upper Hudson River was dredging and securely encapsulating the contaminated sediments. The committee further found that not only was such action environmentally sound but that no other method could be considered as having reached the stage of engineering applicability. From 1977 to 1983, PCB values in the water, suspended sediments, and fish (both upper river and estuary) declined (Armstrong and Sloan, 1980, 1981; Sloan et al., 1984, 1983, 1988~. This decline was popularly ascribed to natural cleansing of the river, however, a contrasting argument could be made that the decline resulted from two actions taken by the state and from one natural cause. The actions taken by the state were 1. forcing GE to stop its PCB discharges (ended July 1, 1977), and 2. carrying out two large-scale cleanup operations at Fort Edward and taking care of the most contaminated of the remnant deposits. The natural action was lower rainfall, which resulted in less erosion of PCB-contaminated sediments (Barnes, 1987~. Since 1983, PCB values in striped bass in the estuary have varied with discharge. When discharge increases, PCB values in striped bass increase, and vice versa (Sloan et al., 1984, 1988~. Three major unresolved issues related to the resolution of PCB pollution in the upper river are 1. depth of scour of bed sediments during floods; 2. significance of selective dechlorination of PCB congeners by anaerobic bacteria; and 3. whether the Hudson River flow varies cyclically over 20 years. The depth of scour during floods determines what thickness of bed sediments will be mobilized into the water column, each of them only temporarily, during the flood. The stirred-up sediments move some dis- tance downriver, and then, as the flood wanes, are placed back on the bed of the river again. Proof that hot-spot boundaries in the Thompson Island Pool have not shifted since the 1974 and 1976 floods (Brown and Werner, 1985; Brown et al., 1988) is consistent with the expectation that no such shifting should have taken place because the post-1976 floods have not attained the flow levels of the pre-1976 floods. Congener-specific analyses of PCBs in selected hot-spot sediments (Bopp et al., 1984; Brown et al., 1984, 1987, 1988; Bush et al., 1986; Simpson et al., 1984) and followup bacteriological studies have further

377 proved that the low-chlorine PCB congeners found only in these hot-spot sediments beneath their surficial cover have resulted from the actions of anaerobic bacteria. Such low- C1 congeners have not been found downriver; they offer additional proof that locations of the boundaries of the hot spots defined in 1978 have not changed. What is yet to be determined is the minimum PCB concentration at which the anaerobic bacteria are capable of selectively dechlorinating the high-Cl PCB congeners. Such selective dechlorinization has been reported to take place at PCB concentrations of 700 ppm in experiments carried out by James Tiedje at Michigan State University (supported by GE). But, no such selective dechlorinization has been found at concentrations of 50 ppm in experiments carried out by Dr. Rhee (Chen et al., 1988) in the New York State Department of Health (supported by NYS DEC and the Hudson River Foundation). The possibility that a 20-yr cycle exists in discharge variation in the upper Hudson River has been reported by mathematical analyses of monthly discharge means. EPA staff rejected this possibility, arguing that the statistical base is inadequate (NUS Corp., 1983~. However, if such a flow cycle does exist, the remedial dredging planned for the early l990s will be done against a background of rising river dis- charges and thus rising ambient PCB values in the water, suspended sediments, and fish. Because of the delays over finding funding from "sources other than GE," and permit delays, the opportunity to carry out a PCB hot spot reclamation demonstration project against a natural background of declining PCB values has been squandered. Rather than being able to claim credit for the results of a dredging project liberally assisted by natural causes, NYS DEC may have to explain why PCB values were higher after the dredging project than they were before. Since 1978, when it recommended dredging and secure encapsulation, the Advisory Committee has kept itself informed on the latest methods of treating PCB-contaminated sediments. The point of this effort has been to be able to recommend final treatment of encapsulated sediments as treatment technology develops (Carpenter, 1987~. The committee recommended spending parts of the money remaining in the settlement fund to pay for contractor experiments with PCB-contaminated sediments from the upper Hudson River. Three successful or partly successful sets of experiments have thus been made. A further delay in starting the final phase of the rehabilitation of the upper Hudson River has arisen from the second Siting Board's rejection of the NYS DEC Project-Sponsor Group's (PSG) application for use of a parcel of land next the the old Fort Edward dump as the pro- posed encapsulation site. NYS DEC ruled that PSG must re-apply for a parcel close to the river in southern Fort Edward and the site for which the certificate and DEC permits granted by the first Siting Board in 1982 were voided by a 1984 State Appellate Court decision. More- over, NYS DEC ruled that the application for use of Site 10 must request not just secure encapsulation, as in the previous two requests, but also must include available processes for stripping PCBs from contaminated sediments and/or destroying the PCBs, and it must deal with not merely the sediments from the 20 hot spots in the Thompson

378 Island Pool but also from the remnant deposits, from old NYS DOT dredge-spoil sites, and from the 20 hot spots between Thompson Island Dam and Troy. This ruling is a return to the scope of the cleanup recommended in 1978 by the Advisory Committee, but which was rescoped downward to fit available funds. Still undetermined is when EPA will decided that its "interim period of evaluation" under Superfund I is over and that its Record of Decision (ROD) of July 1984 be revisited. In July 1984, the Food and Drug Administration (FDA) action level for PCBs in fish was 5 ppm. In August 1984, this level was lowered to 2 ppm. As of 1988, PCB values in fish have not declined much below 5 ppm. Accordingly, the 1984 ROD's projection about fish has not materialized. Recently issued report by New York State on the necessity to add water from the Hudson River to the drinking water supply for the New York City metropolitan area represents a further public-health issue not considered in EPA's 1984 ROD. Accordingly, EPA's Superfund evaluation that recommended no action with respect to removing PCB-contaminated sediments in the upper Hudson River needs to be revised. A final factor in the delay over taking any remedial action with the PCB-contaminated sediments in the upper Hudson River has been the ambivalent attitudes of the citizens of Fort Edward. They favored what they considered to be beneficial dredging operations, but opposed any dredging operations whose objective was rehabilitation of the upper Hudson River. In 1974-7S and again in 1977-78, the state's cleanup operations 1. 2. 3. repaired and protected their water-supply pipes where they cross the Hudson River at old Fort Edward Dam site; reopened their oil terminal for barge traffic; and unplugged blocked dewage outfall pipes to restore water flow in the east channel past Rogers Island, thus enabling the raw sewage they were dumping into the river to be carried away downstream once again. Fort Edward citizens clamored for these operations and did not oppose dredging nor the spreading of the dredge spoil on Rogers Island. By contrast, starting in 1982, they opposed every proposal to rehabilitate the upper Hudson River by dredging and encapsulating the dredge spoil in a specially engineered facility to be located in Fort Edward. Moreover, they expressed satisfaction with the idea that no action at all would result in the river eventually eroding the polluted sediments and redepos iting them downriver. ASSESSMENT OF CONTAMINATION Assessment of contamination of the Hudson River began when high levels of PCBs were found in striped bass caught in the lower river (Boyle, 1975~. Once the problem had become public and the GE plants at Hudson Falls and Fort Edward were identified as the point sources, attempts were made to assess the extent of contamination. One approach

379 was to compile GE' s records of purchases of PCBs from the sole American supplier, Monsanto Industrial Chemicals Company; another approach was to collect core samples of sediments, analyze their PCB contents, and compute the quantities of PCBs discharged into the upper Hudson River. The following sections summarize these endeavors. PCB Levels in Fish As early as 1969, samples of biota from the upper Hudson River were found to contain high levels of PCBs. Robert Boyle's program of col- lecting specimens of coastal game fish and analyzing them for pesticide residues, mercury, and PCBs brought the problem to the public's atten- tion. The Wisconsin Alumni Research Foundation (WARF) Laboratory in Madison, Wisconsin, analyzed the samples. The specimens were shipped in dry ice without ever being wrapped in plastic. High PCB values were found in most of the fish. The highest values were in the Hudson River striped bass, 4.5 to 5 ppm in the fish flesh and 11 to 12 ppm in the eggs. Boyle communicated his results to NYS DEC, but got no response. (He learned later that NY State's response was to begin to test fish. They did not publicize their results until August 1975.) The signifi- cance of the Hudson River striped bass specimens was that they showed elevated levels of PCBs even before the Fort Edward Dam had been re- moved in 1973 and thus prior to the great downriver surges of PCB- contaminated sediments in 1974 and 1976. EPA Region II staff collected fish from the upper Hudson River, downstream and upstream from the GE discharge pipes. They found clean fish upstream, but heavily contaminated fish downstream from the two GE plants (Nadeau and Davies, 1974, 1976~. In September 1975, NYS DEC announced that PCB concentrations in a bass caught near the GE plants were 350 ppm. The averages of several catches in August 1975 at Waterford were 41.5 and 53.5 ppm in small- mouth bass, 28.2 and 48.9 ppm in white suckers, 32.4 ppm in walleyed pike. Table 2 shows PCB values in fish caught during 1975-76 in various parts of the Hudson River. Analyses of Sediment Samples Sediment samples from the upper Hudson River have been collected and analyzed for PCBs by NYS DEC, EPA, and contractors. A systematic collection was made as part of the comprehensive study made possible by the GE settlement fund. NYS DEC contracted with Normandeau Associates, Inc. (1977) of Bedford, New Hampshire, for detailed mapping and sediment collecting in the upper river. Normandeau collected 312 short cores from channel-margin flats in the upper Hudson River, and 600 grab samples on 40 transects at approximately one-mile intervals between Fort Edward and Waterford. The 672 analyses for total PCB by O'Brien & Gere (1978) formed the basis for the NYS DEC map of 40 hot spots (Figure 7) and computations of sediment volumes and PCBs concentrations

380 TABLE 2 PCB Values in Fish Caught in the Hudson River during 1975-76 Location Species Number Total PCB (ppm) of fish Average Low High Upstream of Smallmouth bass 26 Trace Hudson Falls Yellow perch 15 Trace Fort Edward to Smallmouth bass 11 72.6 41.5 122.9 Federal Dam Yellow perch 10 134.6 79.3 299.3 (Troy) White sucker 37 68.2 28.2 131.4 Largemouth bass 37 61.7 12.5 164.4 Federal Dam to Yellow perch 5 5.28 Battery Largemouth bass 10 lO.OS 1.73 23.74 White perch 23 10.08 5.28 19.88 SOURCE: Horn et al., 1978. in the sediments (Figure 8~. The PCB content of the Thompson Island pool was calculated to be 61 tonnes (MPI, 1977c; 1978a, 1978b, 1979, 1980a, 1980b, 1980c, 1981; Tofflemire et al., 1979a, 1979b). Figure 9 summarizes the aggregate distribution of PCBs with depth in the core samples collected in the Normeandeau I operation. In order to obtain a clearer understanding of the nature of the channel-floor coarse sediments that had proved so difficult for Norman- deau's coring attempts, Steve Selwyn and I used a box corer that he had designed and built to collect four samples from the Thompson Island pool between Normandeau transects 7-4 and 7-6, at Hot Spot No. 5. Dr. James Tofflemire, of NYS DEC participated in the operation by arranging for NYS DOT assistance, selecting the coring sites, determining posi- tions with an optical range finder, and arranging for analyses. The box corer measured 0.5 x 0.5 x 1.5 m. The box was rigged so that it would fall freely to the bottom from just beneath the water sur- face after a trigger weight attached to the end of a release lever arm had touched bottom, thus allowing the release lever to swing upward and open the release clamp. After the box penetrated the sediment, the upward pull on the wire rope would activate the jaws, drawing them shut and preventing the sediment from escaping out the bottom. In their open position, these jaws fit closely along the outside of the box. The box had been constructed so that the vertical plate on one side could be unbolted. Therefore, after a box had been retrieved from a drop, we would lay it on the side opposite the removable plate, unbolt and remove the plate, and thus reveal a view of the sediment on a plane that was perpendicular to the water/sediment interface. At site BC-ll, the box corer was attached to a pile driver and pounded into the bottom sediments by repeated blows. This pile driver coring was done by NYS DOT work crews downstream from where they had been installing sheet piling. They drove the box corer in to a point of refusal, which was reached after the box had penetrated nearly its

~ 381 i.''' ~ ~ Jan '''I ~ An' _-- ~

°L lo. t E 30 LU J 40 ~ 50 UJ 0 60 A s JO ! 9°'1 100 1 clot 120— 382 coo - - (Downst~catn) Rasped 9.8 CONCENTRATION PCB IPpm) 0 40 1 80 120 ,.~., ~ ' ~ ~ . ~ T r 1 9% ~.1 N ~ 87 58% | N - ! AL . -, . ., '- 36~ "' ~ ~ 36 . .. ,. ~ N ~ 63 1 ,,.,. __ 1 25% N ~ 27 _ _ ; ~ N.9 or 1D 20 - E ~` J hi: 8 I s 0. c Reaches 7 {Tho~npeon l~landl, 6 CONCENTRATION PCB (ppml 0 40 1 80 120 160 0 do 1 80 ~i'^// ~ ~ ~ al ~ ~ I O it I ~ I I ;//, 40 4% ~/ N ~ 47 1 N · 44 10- ~ N ~ 2: 20- N ~ 62 N ~ 22 40 - _ so ITS · 6 60 ~0 _ 80 70 so 1 90 J 1 100 - _ N.A N Number of sample ·~lVzed Proportion of temple' thel ·~ ~ ~ _ . Bar thicknff~ corre Pond _ to eve depth ... 100 - _ sow Reach. St CONCENTRATION PCB (ppm) PIN. 1 90~ ~ FIGURE 8 PCB analyses sediment samples selected from 312 short cores collected from channel margin flats along the upper Hudson River, grouped according to reaches (1) 9 and 8 north of Thompson Island Dam, (2) 7 and 6 between Thompson Island Dam and Lock 5, and (3) 5 to 1 between Lock 5 and Troy. High PCB values above the 90-cm level in reaches 8 and 9, and above the 45-cm level in the other reaches, mark the flow of April 1974, when debris from the then-newly exposed remnant deposits surged downriver after removal of the Fort Edward Dam. SOURCE: Hetling et al., 1978. RIVER 219 USE 7-5 7~ 220 0 ~ ~ i' ~ ~ ll 5 ~ 3 1 0 HOTSPOT 5 ~ ! - hi ~ ' ~ — `~218 ~ , l 217 i? ~ ~ ~ ~ _ - -—Normanaeau transect O Box dredge stations, 1979 O Normandeau sample stations nar grate samples(1-s) 11/14/79 Ponar grab samples (6,7) 11/21/79 \ ~< Lagoons 50' stakes FIGURE 9 The northern part of Thompson Island pool near hot spot 5, showing Normandeau transects (dashed lines) and sampling stations (circles), NYS DEC ponar grab samples (triangles), and box cores (squares) collected in August (BC1, BC2, and BC3) and September (BCll). Areas marked lagoons are part of Special Area 13 of NYS DOT dredge-spoil sites.

383 Sketch from peel FIGURE 10 Sketch of relief peel made when the box corer was first opened and samples collected for PCB analyses. Subunit TotalPCB(pgg~~) A, B 13.7 56.5 /~3.8~ - \ G (not on peel) entire length into the sediment. When the box was opened, we found 42 inches of sediment within the rectangular part and another six inches in the closing jaws. We sketched the relationships visible on the vertical face of the contents of the box and collected samples for PCB analysis. Then, after several attempts, we finally made a successful relief peel using the techniques described in Burger et al. (1969~. Figure 10 shows the relief peel with lettered subdivisions that selected for PCB analyses. The numbers are total PCBs expressed as parts per million on a dry-weight basis. The large relief peel from station BC-ll gives a dramatic indica- tion of the kinds of debris that washed into the northern end of the Thompson Island pool as a result of the 1974 and 1976 post-dam-removal floods. Two remarkable features stand out: t 6

384 1. the steep inclination of the layers in the lower part, and 2. the distribution of PCB values. At first sight, the steeply inclined layers might be considered to be an artifact of the coring operation. However, the fact that the topmost layer is horizontal proves that the inclination is natural. I interpret the steep dip as oversteepened cross strata that resulted from flow across a shallow area into a deeper area. ~ infer that the sediment being swept across the shoal avalanched into the deeper water but that the dip was steepened well beyond its normal angle of repose because of flow up the slope that was associated with a separation eddy (Friedman and Sanders, 1978~. The fact that the high concentrations of PCBs are found only in subunits C through A' indicates that these lay- ers were deposited since the 1974 flood. As part of their assignment in preparing the Superfund I Remedial Action Master Plan (RAMP), NUS Corp. (1983) re-examined hot spots that NYS DEC had mapped in the Thompson Island pool based on the Normandeau I cores (1977-78~. NUS found that no hot spots had disappeared, but the mapped values needed revision. Accordingly, NUS recommended to EPA that all the hot spots in the Thompson Island pool be remapped. A detailed re-survey of Thompson Island pool hot spots was mandated by EPA as part of its funding eligibility requirements, and 400 sedi- ment cores and 600 grab samples were collected and analyzed (1985; Nor- mandeau Associates II). After all the PCB results had been submitted to NYS DEC, the results were summarized using NYS DEC's newly organized computer programs. The concentrations of PCBs were integrated at depth intervals of 0.5, 1.0, and 1.5 m. Approximately 95 percent (21.9 tonnes) of PCBs were found to be in the top 0.5 m, and 99.91 percent (23 tonnes), in the top 1 m. The total value of 24 tonnes for the PCBs in the Thompson Island pool hot spots is significantly smaller than the 61 tonnes calculated in 1978 (Brown and Werner, 1985; Brown et al., 1988~. These results served as a basis for recalculating all the previous estimates of the PCB budget in the Hudson River (Figure 11~. Other cores have been collected in the upper river by John Brown of GE (Brown et al., 1984, 1987) and Richard Bopp of Lamont Doherty Geological Obervatory (Bopp and Simpson, this volume). Both have analyzed for individual PCB congeners, instead of for comparison with a given standard or total PCBs. The have found evidence that the lower chlorinated congeners are being enriched relative to the higher chlorinated congeners. According to the experimental evidence later presented to Siting Board II by Dr. James Tiedje, these changes have resulted from the effects of anaerobic bacteria. The congeners being formed by bacterial action are unlike those thought to have been washed into the river from the GE plants , are unlike those being transported downriver sampled by Bopp and Simpson, and are unlike those found by Bopp and Simpson in the lower river. These f indings supply further proof that the hot spots are not being eroded and are not contributing to the downriver migration of PCBs as sampled by the USGS.

38S DREDGED (4) (31.68%) / FROM UPPER RIVER / REMNANT (2) (12 DEPOSITS 1 60,000 64.O00 ' 1 00,000 — TRANSPORTED TO \ LOWER RIV(1 ) (25.74%) 1 3O,000 \ 1 . i 51 ,000 / 1 .1. POOL(5) (10. 10%) ~(3) (19.80%) EXCLUDING T.l. POOL FIGURE 11 Revised budget for PCB discharge 504,000 pounds. Sources of estimates: Brown using data from Bopp and USGS, Tofflemire and Quinn (1979), Brown roughly reducing 1978 estimate in light of errors, Horn et al. (1979), Brown et al. (1985~. Organisms Other Than Fish Although most of the early attention to PCBs in organisms concentrated on fish, because of human health concerns, many other parts of the biota proved to contain PCBs: for example, snapping turtles (Stone et al., 1980), aquatic intertebrates (Werner, 1981), caddisflies (Simpson et al., 1986), and plants (Weston, 1978; Buckley, 1982, 1983, 1987~. The results of PCB measurements in plants (Table 3 support the conclusion that the PCBs found in plant samples come from the atmosphere. Evaluation of Threat to Food Chain and Human Health The main basis for evaluating activities with respect to Superfund sites is impact on human health. At least five threats of PCBs to human health have been evaluated: 1. - from contaminated sediments and water into various organisms and up the food chain to fish and from contaminated fish to

386 TABLE 3 PCB Concentrations in Plants from Selected Localities in Upper Hudson Valley Region PCB concentration (Total PCBs; milligrams per gram, drY-weight (basis) Lower Upper Lower Upper Cores from leaves leaves twigs twigs trunk, 1 to (0-2 m) (ca 5 m) (0-2 m) (ca 5 m) 1.5 m; bark discarded Location and species Caputo dump: Pitch pine 317 81.2 White pine 215 Quaking aspen 89.6 28 87.1 17.7 1.2 120 1.16 SOURCE: Hetling et al., 1977 people who eat fish; 2. from drinking water (either ground water from wells in the upper Hudson area generally but near old PCB dump sites in particular or from public water supplies drawn from the Hudson River; 3. from forage crops and vegetables grown near the upper Hudson River; 4. from direct contact with highly contaminated sediments; and 5. from the atmosphere. - The most direct and substantial source of PCBs into people is via ingestion of contaminated fish. Accordingly, many fish have been caught and analyzed to determine both the geographic extent of such pollution and any changes through time. The publicity over the discovery of high levels of PCBs in 1975 prompted NYS DEC to close the entire upper-river sport fishery and the commercial fishery for striped bass and eels in the Hudson estuary (a ban extended in 1984 to include the striped bass from Long Island Sound and the New York Bight after the FDA lowered its action level for banning fish from the market place from 5 to 2 ppm). As noted earlier, EPA's Superfund 1984 ROD for the upper Hudson River concluded that human health was sufficiently protected in New York state by enforcement of the fishing bans and reliance on ''nature's remedy," which they took to be operating in the river to bring the aver- age level of contamination of Hudson River fish below the FDA 5-ppm action level. With the change to 2 ppm, any new evaluation will find that PCB contamination in fish exceeds the FDA action level. EPA's 1983 Superfund RAMP concluded that Uaterford's public water supply should be evaluated from the point of view of the possible threat to human health from drinking water from the Hudson River. Over

387 TABLE 4 PCB Concentrations in Air Samples from Selected Localities Compared with Upper Hudson River Area Location (date) Number Range Comment of (nanograms on Aroclor samples per m ~ or other information SELECTED LOCALITIES Vineyard Sound, MA (1973) 02 04-05 Calc. as 1254 University of RI (1973) 2.1-5.8 do Providence, RI (1973) 9.4 do Chicago, IL (1975-76) 04 3.6-11 4% as 1242; - 97% as "vapor" Lake Michigan (1976-78) 06 0.57-1.6 74% as 1242; 88% as 'ivapor'' Milwaukee, WI (1978) 02 2.7 59% as 1254; 27% as 1260; 84% as "vapor' UPPER HUDSON RIVER AREA Average Washington Co. offices (Nov 76 to Jun 77) 31 990 Air pumped for 24 hr through a fluoris il column (Jul 77 to Nov 77 15 305 Fort Hudson Nurs ing Home (Nov 76 to Jun 77 ~ 23 108 (Jul 77 to Nov 77) 10 25 Main Street, Fort Edward (Nov 76 to Jun 77 ~ 24 102 (Jul 77 to Non 77 ~ 12 67 Glens Falls (Nov 76 to Jun 77 ~ 32 < 20 (Jul 77 to Nov 77 ~ 09 ~ 20 Warrensburg (Nov 76 to Jun 77) 25 < 20 (Jul 77 to Nov 77 ~ 07 < 20 Caputo dump (Nov 77 ~ 05 3, 240 3 2 . 5 -hr samples; 2 08-hr sampl es Fort Miller dump (Nov 77 ~ 03 2 ,160 08 -hr samples New Moreau fac il ity (Nov 77 ~ 03 107 08 -hr samples SOURCE: Beeton, 1979; Hetling et al., 1978.

388 the years, NYS DEC has repeatedly tested Waterford's water supply, most notably during 1977 and 1978, when the much-monitored NYS DOT channel maintenance dredging of Fort Edward terminal took place. During these operations, no changes in PCB level in Waterford's intake could be detected. NYS DEC also monitored the intake of Poughkeepsie's water treatment plant, but gave it up in 1979 when the levels persistently dropped below detection level. The chief places where people might come into direct contact with contaminated sediments are the remnant deposits. The significance of this route was emphasized by EPA's Superfund RAMP. As a result, EPA recommended that the remnant deposits be contained by capping them with 18 inches of soil. However, EPA's July 1984 ROD, indicates that The appropriateness of further remedial action for these sites will be reexamined if EPA decides at a later date to take additional action with respect to sediments in the river. Nationwide, the atmosphere is the largest natural source of PCB transport (Beeton, 1979~. Table 4 compares PCB concentrations in air samples nationwide with those found in ache upper Hudson valley. REMEDIAL/ALTERNATIVE TECHNOLOGI ES Evaluation Methodology Initally, NYS DEC and the Advisory Committee evaluated claims of new schemes for PCB destruction and evaluated them against the known engineering realities of dredging and encapsulation. In addition to these efforts, EPA's contractor, NUS Corp. (1983), presented a list of known PCB-destruction processes, but nearly all of them were for PCBs in oils. Only a few dealt with destruction of PCBs in sediments, and they all presupposed dry sediments. Although EPA's 1983 Superfund I evaluation of PCBs in the upper Hudson River rejected dredging, none of the alternative technologies reviewed can in any way be considered as a realistic alternative to dredging and encapsulation. NYS DEC supported contractor experiments with Hudson River PCB- contaminated sediments. So far, successful thermal stripping of PCBs has been achieved by American Toxics Disposal, Inc., of Waukegan, Illinois, and PCB reduction has been achieved by the use of triethyla- mine, taking advantage of its reverse immiscibility with water/oil at 70°F, a process developed by Resources Conservation Corp. of Belle- vue, Washington. PCBs have been both removed from sediments and des- troyed in the Wright Malta steam-gasification process. Technologies Considered and Their Costs In 1978, when the Advisory Committee recommended to NYS DEC that dredging was the best way to begin rehabilitating sites with PCBs in excess of 50 ppm (the hot spots) and that secure encapsulation facility

389 should be constructed close to but out of the river, the only available process for destroying PCBs in contaminated sediments was incineration. Cost estimates for incineration (estimated at $130/m ; $100/yd3) were based on the GE-Nichols Engineering tests with Hudson River hot spot sediments (Nichols Engineering Research Corp., 19789. These tests yielded estimates based on energy costs calculated when crude oil was $14 per barrel. It was widely believed that the price of oil would continue to rise, increasing incineration costs beyond what was affor- dable. Incineration was thus rejected as a final solution. Since there was no other tested PCB-destruction process capable of use on sediments, NYS DEC and the Advisory Committee agreed upon that safe encapsulation, perhaps for many years or even tens of years. Meanwhile, they continued to search for reasonably priced methods for stripping PCBs from the sediments of PCBs or destroying them. From 1978 to 1988, many methods for destroying PCBs in contaminated sediments have been proposed. In 1986, EPA Research Laboratories in Cincinnati commissioned engineering analyses of PCB-destruction pro- cesses. A final report (Carpenter, 1987) evaluated how various methods might apply to the upper Hudson River hot spots. The Carpenter report found three methods other than incineration that could be used to treat PCB-contaminated sediments once they were dredged from the river: 1. Basic Extraction Sludge Treatment (B. E. S. T.) process of the Resources Conservation Co. of Bellevue, Washington; 2. ozone-ultraviolet exposure in an ultrasonic bath developed by Ozonic Technology of Closter, New Jersey; and 3. microbial scheme of Bio-Clean, Inc. of Burnsville, Minnesota. Two other processes have been or are being investigated by NYS DEC and the Advisory Committee that were not considered in Carpenter, 1987: PCB stripping by a rising current of heated air (American Toxics Disposal, Incorporated, Waukegan, Illinois), and steam-gasification (Wright Malta, Inc., Ballston Spa, New York). Remedial Action Selection Criteria No process has been proposed that constitutes a viable alternative to physically removing PCB-contaminated sediments from the river as a first step in final rehabilitation. The Advisory Committee believes that the proposed dredging will not involve large-scale, long-distance downriver migration of PCB-contaminated sediments as a result of the disturbance of bottom sediments that inevitably accompanies dredging. Actual dredging operations monitored in 1977 demonstrated that at low- flow stages of the river, when dredging takes place, gravity pulls the stirred-up sediment back to the river bed in the vicinity of the dredge. Indeed, no increased levels of PCB concentrations were detec- ted one mile downriver from the dredge. That highly contaminated sedi- ments can be encapsulated securely was demonstrated when the highly contaminated sediments from the second cleanup of Fort Edward terminal in 1978 and from area 3A of the remnant deposits were placed in the new

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.

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

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.

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

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.

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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The pervasive, widespread problem of contaminated marine sediments is an environmental issue of national importance, arising from decades of intentionally and unintentionally using coastal waters for waste disposal. This book examines the extent and significance of the problem, reviews clean-up and remediation technologies, assesses alternative management strategies, identifies research and development needs, and presents the committee's major findings and recommendations. Five case studies examine different ways in which a variety of sediment contamination problems are being handled.

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