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Housatonic Before and after PCB cleanup in the first 1/2 mile

PCBs under the water table in Pittsfield, Mass.There is a different side to the story when you hear GE and some people say that the clean up didn’t work in the Pittsfield two mile stretch of the Housatonic River. Here is what was found during remediation. This is Dense Nonaqueous Phase Liquid. A mixture of PCBs and other toxic chemicals on the bottom of the river. Some of these plumes that were discovered during the clean up had PCB concentrations thousands of times what EPA considers safe.  GE , Mass DEP, and Mass Fish and Wildlife are using this stretch of the river to imply the clean up destroyed the river.

Housatonic river restored after PCBs removal

Housatonic River five years after PCB cleanupOther parties to this discussion don’t show pictures after restoration has been allowed to take hold. They only show you the river during and immediately after dredging. Restoration takes time!The picture on the left shows the first half mile with 10 years of growth. Below is a picture of the second mile and a half clean up with five years of growth. So do we clean the PCBs and restore the river or leave the PCBs where they are?

Housatonic River tens years after PCB cleanup

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Housatonic River PCB Cleanup Plan from EPA has sever shortcomings

Press Update- for immediate release

September 18, 2014       For more information:

Henrico Virginia             Dr. Peter L. deFur

cell 804-690-4153          Office 804-741-2922

Housatonic River PCB Cleanup Plan from EPA has sever shortcomings In June 2014, EPA released the Draft RCRA permit (Permit) and the Statement of Basis (Basis), which together form the Proposed Cleanup Plan (Plan) for the HousatonicRiver “Rest of River” PCB Superfund site.  A public comment period is currently underway and provides an opportunity for the public and interested parties to discuss concerns with EPA’s Plan. Comments close Oct 27, 2014. Environmental Stewardship Concepts (ESC)believes the current cleanup plan is insufficient within the framework of human an environmental health. The purpose of the cleanup is to restore the site to a state where i poses a minimum danger to human or wildlife that live in and around the river. EPA’s Plan simply will not do so. We would like to bring this to your attention through a brief summary of the major issues raised in our comments on the proposal. The Housatonic River was heavily polluted with PCBs by releases from a General Electric plant in Pittsfield, MA that occurred repeatedly between 1932-1977. While cleanup has been completed near the GE site, the “Rest of River”, divided into Reaches 5-16 (see Figure 1), remains contaminated.  The EPA’s preferred solution would involve excavating and/or capping (covering with an impermeable layer) sediment in select areas of the river Sediment in reaches 5 (A, B, C) and 6 at or above a certain threshold PCB concentration would be excavated and capped; unfortunately, EPA varies this removal threshold from 1 to 50 parts per million (ppm) without providing a rationale for doing so.  Furthermore EPA suggests Monitored Natural Recovery, or essentially taking no action while monitoring PCB levels, for the vast majority of the remaining river, reaches 7-16. EPA estimates that 25% of the PCBs will be removed under this plan. This plan would leave large amounts of PCBs in place at concentrations known to be dangerous to humans and wildlife. There are a number of factors EPA is not adequately taking into account. First, capping is an impermanent solution at best. Contaminants that have been covered can be uncovered by changes in the river channel, erosion, and especially through flooding or major storm events.  EPA’s Plan only accounts for the possibility of a 10 year storm when most climate change experts agree that the probability of 100 year storms is currently higher than ever. Secondly, the EPA also allows for PCB concentrations as high as 50 ppm without any action in several reaches; a 50 ppm cleanup is simply inadequate to protect wildlife, human health, or to prevent further contamination down river. While EPA includes no recent documentation to suggest these levels are safe, current literature on PCB toxicology indicates increasing evidence that PCBs are toxic at lower concentrations than previously considered. The International Association for Research on Cancer (IARC) recently classified PCBs as known human carcinogens and non-carcinogenic health effects have been found in nearly every major body system1.

An ESC memo on PCB toxicology in humans and wildlife as well as an extensive literature review will bepart of official comments to EPA.

The EPA also fails to address the full extent of the potential for carcinogenic effects in humans fromPCB exposure through fish consumption. The Plan sets an interim performance goal of reducing PCBs in fish tissue to 1.5 ppm within 15 years and 0.064 ppm in the long term. Unfortunately these targets would exceed the EPA’s own fish consumption recommendations, which call for no more than 0.024-0.048 ppm of PCBs in fish tissue concentrations for a single meal of fish a month. This error is particularly problematic in the Housatonic River where subsistence and recreationalfishers frequently consume many times more than one meal of fish a month.

Finally, several of the EPA’s recommendations in this plan are not substantiated by any clear precedent or rationale.  For instance, the Plan calls attention to certain “Areas of Critical Concern”, or Core Habitats, in which state-listed, or otherwise ecologically important species reside.  However, rather than recommending more stringent cleanup standards to ensure the best possible outcome for the habitat and its species, the Plan recommends leaving the PCBs in place.  The EPA suggests that cleaning up the PCBs could harm the state-listed species by disturbing the contaminants in the removal process.  However, as we have already seen with the near disappearance of mink in this area, leaving PCBs in place is not an effective solution.

PCBs persist in the environment and in wildlife, becoming more concentrated and toxic as they move through the food chain. In short, PCB concentrations are not naturally decreasing  fast enough to matter for the most vulnerable species. On the other hand, studies of PCB remediation have shown that while a full scale clean up can increase PCB concentrations in the short term in some cases, after removal, the concentrations decrease rapidly and species and habitat recover.  We understand EPA’s recognition of core habitats in the Housatonic, but it is not clear how core habitats were determined or why they would require less clean up

Similarly, the EPA suggests using Woods Pond (Reach 6) as an intentional catch basin for PCB contaminated sediment that is transported down river as a result of erosion and scour.  Woods Pond is a unique habitat in the river valley and EPA provides no rationale for why this would be an acceptable area to allow PCBs to concentrate. The need for such a “catch basin” is largely a response to inadequate removal upriver.  If the Plan called for more aggressive removal, there would be less PCB contaminated sediment available to transport.

Finally, EPA did not specify any precedent study or research that indicated the effectiveness of maintaining a catch basin, nor any research indicating the safety of doing so.  It is irresponsible to propose such actions without fully investigating the plausible repercussions.

Perhaps the most alarming aspect of the EPA’s  Plan is the intent to waive the Federal and State human health water criteria of  less than 0.064 parts per trillion (ppt) in water for reaches 5-9.  The Plan suggests that reducing PCBs below the criteria in this portion of the river is technically impractical. Such statements on the part of an agency tasked with preserving human health and the environment are troublesome at best. As the science increasingly indicates PCBs are a significant threat, the public deserves a cleanup plan that addresses the impracticalities that stem from relying on outmoded remediation tools such as capping and monitored natural recovery (MNR). Due to their chlorination, PCBs are highly resistant to natural degradation and persist in sediment and in wildlife for decades or longer. While MNR can work for contaminants that readily degrade in sediment through microbial activities, the research shows that MNR is minimally effective for persistent chlorinated organic chemicals. Nevertheless, the EPA’s Plan calls for implementing MNR for reaches 7- 16 of the “Rest of the River” project and as a result will fail to meet the primary federal human

PCB remediation technology has advanced considerably in the last decade2 and it is unclear why the EPA fails to acknowledge options such as bioremediation or sediment washing. Despite several viable alternatives, the Plan’s only recommendation for modern technology comes in the form of a pilot test for capping using a form of activated carbon. Activated carbon is only a modification of traditional technology and still results in the contaminants remaining in the sediment.  The pilot study is also too small in scale to have any significant effect on the project area as a whole.  Numerous studieshave been published documenting the success of new remediation technologies. Toxic contamination, especially when found in a river, must be examined in a larger context. The Housatonic drains into Long Island Sound.  The Long Island Sound feeds the Atlantic Ocean, which feeds the world.  By failing to effectively clean up the Housatonic River,

EPA is not only failing the human and wildlife communities of the Housatonic, but also those of our planet at large. PCBs are found in the remotest reaches of North Pole and deep in the ice of Antarctica; they are an international problem that must be treated as such. To only half address this contamination will mean continued additions to the global PCB load for the foreseeable future.  In addition, major projects such as the Housatonic river clean up act as precedents for future clean ups. It is important that the EPA and the responsible parties implement the correct approach now.  By that token, it is also important that the public maintain pressure on those making these critical decisions.

ESC, LLC is the technical advisor to the Housatonic River Initiative on the PCB site and

prepared this press announcement without the use of any outside funding, federal, state or

2 An earlier ESC memo on remediation technologies for PCBs is on the ESC website, estewards.com .

Figure 1: Map of the Housatonic from EPA Basis Document

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