Tuesday, May 20, 2008

Susan Svirsky

Rest of River Project Manager

United States Environmental Protection Agency

c/o Weston Solutions

10 Lyman Street

Pittsfield, MA 01201

Sent via email to: Svirsky.Susan@epamail.epa.gov

RE: EPA GE-HOUSATONIC RIVER SITE, CORRECTIVE MEASURES STUDY PUBLIC COMMENTS

Dear Ms. Svirsky,

We the undersigned urge the Environmental Protection Agency to reject the recommendations of General Electric’s Housatonic River “Rest of River” Corrective Measures Study. Instead, we ask that the EPA require GE to follow a process that takes full advantage of new science and technology, includes meaningful community input throughout the cleanup process, and truly addresses the entire “rest of the river,” from the sources of its ongoing PCB contamination in Berkshire County to its outlet in the Long Island Sound. We represent a broad coalition of environmentalists, sportsmen, municipal and other agencies, and ordinary families who work, play, and live along the river. While we are motivated by a wide range of interests and concerns, we are united in the principles set forth in this letter.

Our goal is simple: We want GE to return the river largely to the condition it was in before they polluted it. We want our families to be able to swim and fish in the river, as they once did, without fear of contamination. We want mink and otter and eagle to live and thrive on the river as they once did. We want the PCBs that GE left behind—which will not break down naturally in our lifetimes—to be permanently neutralized as threats to our communities and our environment. And we don’t want all the trees cut down and the river bank turned into a construction site in the process.

Why GE’s Proposal Is Unacceptable

We recognize that the economic and technological challenges to achieving this goal are significant. We are not demanding a perfect solution irrespective of practicality and cost. However, GE’s proposal will not meet the goal of undoing the damage they have done. Their “solution” is to dig up or cover over large swaths of the Housatonic and dump the highly persistent and highly dangerous contaminants in our communities and along the river itself, using the same techniques that would have been used when Love Canal was a new crisis. Meanwhile, the proposal ignores more than a hundred miles of contaminated river south of Woods Pond and does not eliminate the remaining sources of contamination that continue to release toxins into the river. And after the digging is completed, GE does not provide a credible plan to restore what will be left of the river.

GE’s proposal relies heavily on the same methods that were employed 10 or even 20 years ago. It ignores current data and ongoing research supporting the creative use of new technologies. It also ignores the need for further study of the health impacts of the contaminants on the people who have been exposed to them in Massachusetts, Connecticut, and New York. We want to work with GE, and we don’t expect miracles. But the current proposal can only be characterized as a failure of “ecomagination.”

We are also skeptical that GE’s proposal makes sense from a purely economic perspective. GE has not convinced us that dredging the river and moving thousands of tons of contaminated mud will be less expensive than employing new technologies that could potentially treat the PCBs in place. We also aren’t convinced that monitoring and maintaining large landfills containing the contaminants for fifty years or more will be cheaper than technologies that may be more expensive at first but don’t require the monitoring of toxic waste sites for decades. And we’re skeptical that GE’s cost estimates fully cover the potential expense and legal liability of leakage from those landfills. In addition to being a bad deal for the people of Massachusetts and Connecticut, the “Rest of River” proposal may very well be a bad deal for GE. We believe that the company could get better results for the community at lower cost if a more creative approach were taken.

What Should Be done instead

GE’s proposal extends out fifty years, at the end of which the river will not be fully restored under any of the options that they provide. But we will learn a lot over the course of those fifty years that nobody could plan for today. Scientists will improve upon the new technologies that are becoming available for destroying PCBs, making them cheaper and more effective. We will also learn more about the details of the contamination and the river itself as the cleanup progresses. Even the very best engineers, scientists and computer modelers could not possibly create a plan for this cleanup today that will make sense even fifteen or twenty years from now.

There is a better way. The EPA can mandate a phased process that addresses the clean-up a few problem spots at a time. Each phase would include pilot testing of new technologies. At the end of each phase, the EPA and the community would evaluate the results of the experiments together, along with any other new developments, and adjust plans for the next phase. By requiring such a plan, the Agency would be honoring the commitment it made to the community eight years ago as part of the agreement that enabled the original consent decree to go forward. At a press conference in April 2000, Region One Director Mindy Luber explicitly acknowledged that the agreement “includes EPAs commitment to identify and potentially test new and innovative treatment technologies.”

We urge the Agency to honor that commitment. Enclosed is a set of principles that we believe could be the basis for a productive and cooperative relationship with GE that would produce better results for the community while improving GE’s brand and protecting its bottom line. We hope that the Agency will consider these principles as the foundations for any plan going forward.

Respectfully submitted,

Berkshire County League of Sportsmen - Mark Jester

Berkshire Environmental Action Team - Jane Winn

Berkshire Environmental Education Network - Jane S. Burke

Berkshire Natural Resource Council - Bryan Emmett

Berkshire Regional Planning Commission - Nat Karns

Berkshire-Litchfield Environmental Council - Star Childs

Citizens for PCB Removal - Charlie and Barbara Cianfarini

Community Development Corporation, South Berkshire - Tim Geller

Green Berkshires Inc, - Eleanor Tillinghast

Housatonic Environmental Action League - Audrey Cole, President

Housatonic River Commission - William Tingley, President

Housatonic River Initiative, Housatonic Riverkeeper - Timothy Gray

Lee Land Trust - Jan Kegler

Town of Lenox, Board of Health

Town of Lenox, Planning Board

Northwest Conservation District - Jean Cronauer, Executive Director

Stratford Action for the Environment - Charles Perez, President

Taconic Chapter of Trout Unlimited - Gene Chague

Town of Sheffield, Board of Selectmen

Rene Wendell, Conservation Ranger, Bartholomew’s Cobble

Dr. Don Roeder, Berkshire Environmental Research Center

Jay Baver

Olga Weiss

Lynn Fowler

Woods and Mary Lou Sinclair

Sarah Flynn

Valerie Andersen

Michael Feldstein

Kathy Kessler

Richard T. Delmastro

Barbara Kellogg

David Martindale

Edward Jordon and Family

Al and Nancy Bertelli

Alan Silverstein

Mary Berle

Enclosures (1)

Tags:   Housatonic Clean River CoalitionNo Comments.

http://www.epa.gov/region01/ge/thesite/restofriver/reports/publicCommentsCorrectiveMeasures/260391.pdf

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This is the story of Berkshire County’s experience with PCBs, a man-made toxic chemical that was used by the General Electric Company (GE) in its transformer and capacitor divisions in Pittsfield, Massachusetts.PDF file

http://www.housatonic-river.com/hri-pcb.pdf

Tags:   ABCs of PCBsNo Comments.

Picture credited to EPA website http://www.epa.gov/region01/ge/thesite.html - check it out

Engineered Channel or Restored River: The Future of

The Housatonic

Five Approaches To River Restoration

Held on Tuesday, September 23, 2008

Crown Plaza Hotel, Pittsfield, MA

A conference was held moderated by Brian Graber American Rivers

9:00 Sign-in, set-up, coffee, conversation

9:30 Introductory remarks, Benno Friedman, Brian Graber, TBA

10:00 Andy Selle, Interfluve

10:45 Wendi Goldsmith, The Bioengineering Group

11:30 Jim McBroom, Milone & McBroom

12:15 Lunch

1:00 Keith Bowers, Biohabitats

1:45 Stephen Souza, Princeton Hydro

2:30 Panel discussion & closing remarks

3:30 Conference adjourns

For more info call HRI

Save the date - More info to follow
Tim Gray

Housatonic River Initiative
165 Bradley Street
Lee,MA 01238
413-446-2520
housriverkeeper@verizon.net

Tags:   Housatonic Restoration ConferenceNo Comments.

By Benno Friedman
Berkshire Eagle
Article Last Updated: 04/01/2008 12:59:53 PM EDT

Wednesday, April 02
SHEFFIELD

Several hundred years ago, an unpalatable hardship was imposed on the citizens of Massachusetts by The British East India Company, a corporation whose thirst for profit, extracted from the colonies, outweighed all other considerations. The citizen response was immediate and ever since referred to as The Boston Tea Party, portrayed in our history lessons as an honorable response to an unjust and abusive power.

Last Thursday, General Electric presented its master plan for the remaining PCBs in Berkshire County, “The Corrective Measures Study,” which appears equally tainted; a self-serving fiat from a nearly departed entity, whose power and influence over this region at one time was without precedent. As GE pulls out of town, the impact of the remaining PCBs will outlast those, who at one time, might have spoken favorably about “The Company.”

The audience was treated to a numbing series of charts and graphs, a product of computer modeling and technical wizardry. As the laser pointer directed our attention to the differences between SED3 and SED8, it was hard to remember that the projections were really about living people and animals, about future generations, about PCBs’ impact on entire ecosystems and species, about how much sickness and how many deaths were acceptable.

One needed to remind oneself that it was not about providing us with the best cleanup and the best technology currently available. The unmentioned subtext is about maximizing GE’s profits.

Cost effectiveness is about trade-offs, about “bang for the buck,” about abstracting “acceptable risk” into a projected bar graph. Morality, responsibility, leadership, partnership within and obligations to a community; none of these concepts are accepted contributions to a bottom line. Hypothetical goals and outcomes, abstracted numbers plugged into a program, generating soothing, color-coordinated visualizations, representations of possibilities, as removed and distanced from real-world consequence as the laser-guided, un-manned missile is from the destruction, loss, pain and death experienced by those on the ground. No one asks the victims if the risk was acceptable.

The time to complete the various cleanup strategies ranged from zero to 51 years. Technologies that not only promise, but deliver the destruction of PCBs are dismissed as unproven, expensive and potentially subject to breakdown. And unfortunately, even the most ambitious GE-derived plan leaves us with fish that cannot be freely eaten and water that cannot be enjoyed at the table. Our resources depleted, our land and river unusable without severe restrictions, The Company has left town for cheaper labor and less regulated pastures. Has our complacency allowed this to be the acceptable byproduct of progress?

General Electric’s preferred plan for disposal of the soil; sweep it under a rug. Dig it up and bury it in nearby, newly created landfills. This would run smack into Mayor Ruberto’s recent published statement that “the landfill will not be in Pittsfield.” A man of integrity, I thank him for his advocacy of an alternative solution. Looking no further than Allendale, it is hard to imagine that Pittsfield or any other community would extend the welcome mat a second time.

Other GE suggestions: Dig it up and rebury it in the river. Seriously. No comment. Or dig it up and bury it in someone else’s backyard, far away from Pittsfield, perhaps in upstate New York or Texas. Aside from the moral issue (which have never been considered, or even recognized) of making our poison someone else’s problem, this solution’s transportation costs begin to get expensive.

How is it possible for The Company to present a proposal that takes 50 years to complete, yet does not take into consideration the speed of innovation, technological breakthrough and unanticipated invention? Minor changes in their study could produce major improvements in the outcome. For example: imagine a 50-year plan that allowed for flexibility and modification as innovation and discovery dictated. Imagine the results if, in 1920, a 50-year design plan had been accepted for a national highway system that did not incorporate flexibility. What a useless, costly failure it would have become had it not incorporated the initially unanticipated change in construction technology and materials, the creation and growth of population centers, the speed, size and design of future automobiles and trucks, etc.

The Company’s proposal is mired in the past, relying on the worst that precedent has to offer. All this from a company that reminds us as often as its advertising budget allows of its “Ecomagination.”

What is best for a corporation is not necessarily best for a community. Could this be a “Boston Tea Party Moment?” To paraphrase, “If we build a protest, will they come?”

Benno Friedman is a member of the board of the Housatonic River Initiative.

<http://www.berkshireeagle.com/otheropinions/ci_8770233#>

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Housatonic River Initiative / Housatonic Riverkeeper

presents

*PCBs in the Housatonic River: *

*What Are The Human and Ecological Risks? *
*Join Dr. Peter deFur one of the world’s leading experts on health and ecological risks from PCBs. Housatonic fish, waterfowl and sediment have some of the highest levels of PCBs in the world. In 2008 the USEPA will issue another decision on whether GE has to clean more of the Housatonic River. *

* Why does everyone have PCBs in their bodies?
* Why do women have PCBs in their breast milk?
* What are PCBs doing to the wildlife?
* What is the Precautionary Principle?
* How persistent are PCBs in the food chain?
* Why are there still fish advisories in Massachusetts and Connecticut?

The free event will be held on *Wednesday, March 5th at 7 pm at the Lenox, Massachusetts Community Center* on Walker Street. For additional information contact: Tim Gray/HRI, 413-446-2520, housriverkeeper@verizon.net, or Judy Herkimer, HEAL, 860-672-6867, healct@snet.net <mailto:healct@snet.net>

*Dr. DeFur is the HRI technical advisor for the human health and ecological risk assessment fro the Housatonic River. He is chair of the Board of the Science and Environmental Health Network (SEHN), President of the Association for Science in the Public Interest, and recently completed a term on the National Research Council Board on Environmental Studies and Toxicology (BEST). Dr. deFur is an Affiliate Associate Professor in the Center for Environmental Studies at Virginia Commonwealth University. *

*Dr. deFur received Ph.D. in Biology (1980) from the University of Calgary, Alberta. He was a postdoctoral fellow in neurophysiology in the Department of Medicine at the University of Calgary. Dr. deFur held faculty positions at George Mason University and Southeastern Louisiana University before joining the staff of the Environmental Defense Fund (EDF) in Washington, DC. At EDF, deFur was involved in policy issues that include habitat preservation and quality, wetlands regulations, water quality analysis and risk assessment.
*

*Dr. Peter L. deFur* has extensive experience in ecological risk assessment regulations, guidance and policy. He is chair of the Board of the Science and Environmental Health Network (SEHN), President of the Association for Science in the Public Interest, and recently completed a term on the National Research Council Board on Environmental Studies and Toxicology (BEST). He served on the NAS/NRC Risk Characterization Committee, completed numerous reviews of EPA ecological and human health risk assessments, and EPA’s Ecological Risk Assessment Guidelines. He also served on EPA’s Endocrine Disruptor Screening and Testing Advisory Committee (EDSTAC), and presently serves on the task force implementing EDSTAC recommendations.*

*Dr. deFur has participated in workshops on the Precautionary Principle and published book chapters and journal articles on the Principle. He is presently involved in several projects for SEHN on the Precautionary Principle.
He is on the Board of Directors of the Coalition to Restore Coastal Louisiana, and peer reviewer for several professional journals. He has published numerous peer reviewed articles, invited perspectives and review articles for the public on subjects ranging from habitat quality to wetlands, toxic chemical and risk assessment. *

*Dr. deFur has experience in the area of endocrine disrupting chemicals, specifically dioxin and related compounds and comparative endocrinology. During the past ten years, deFur has been extensively involved in scientific, regulatory and policy concerning the generation, release and discharge of dioxin related compounds. He has published a number of papers on regulation and policy aspects of these compounds, considered in many ways prototype endocrine disruptors. Dr. deFur has been extensively involved in the EPA reassessment of dioxin since 1991.*

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This is a slide of the Housatonic flooding at sites that were under remediation. It also
shows a HRI member saving an EPA contractors equipment from going under.

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The first PCB Congress (PCB congress.net) enacted the Declaration of Independence from PCBs in 2003. Close to 40 PCB contaminated community stakeholders take a stand!

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HRI believes we need to achieve the best possible PCB clean up in the Housatonic River as possible.

The “rest of river” area has some of the highest PCB levels in sediment, fish, and waterfowl in the country!

PCBs are one of the most pervasive chemicals in the world’s food chain.

The EPA may be here to clean up only once at this point in history.

EPA has used landfilling at many sites as a final decision for disposal. In Pittsfield they are landfilling PCB next to an elementary school in a residential neighborhood. HRI believes this was a major failure in the first EPA decision . You don’t dump chemicals near children!

Treatment technologies exist to reduce PCB levels so as to minimize or not landfill at all. Any landfill must be only a temporary measure.

The Proposal for the Corrective Measures Study, public comments, EPA’s conditional approval letter and other “rest of river” reports can be viewed GE/Housatonic River Site in New England website.

TIME LINE

In March of this year the Actual Corrective Measures Study will be released for public comment.

• GE Submits CMS - March 21, 2008
• EPA Begins Informal Public Input Period - March 22, 2008
• Presentation of CMS - MA and CT - CCC Meetings- March 26 and 27, 2008

Form EPA Corrective Measures Fact Sheet

Evaluation of Cleanup Alternatives Underway for the GE/Housatonic River Site, Rest of River.

Under its legal agreement with EPA, General Electric is currently evaluating potential cleanup alternatives for polychlorinated biphenyls (PCBs) released from the GE facility in Pittsfield, Massachusetts to the Housatonic River/Rest of River.

The Rest of River extends from the Confluence of the East and West Branches in Pittsfield to the Derby-Shelton Dam in Connecticut. Upon completion of the evaluation, GE will submit for EPA’s review and approval a Corrective Measures Study (CMS) documenting this work, including GE’s preferred cleanup plan. EPA will follow the process outlined in this Fact Sheet and make the final remedy selection decision.

This fact sheet summarizes the CMS process, the alternatives and technologies being evaluated, the evaluation criteria that will be used by EPA to select a cleanup plan, and the opportunities for public input to the process.Copies of the CMS Proposal and other Rest of River documents are available for public review on EPA’s website - www.epa.gov/ne/ge.

Download PDF: Corrective Measures Study (CMS) Process Fact Sheet Housatonic River “Rest of River, October 2007

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Americans Rivers, a Washington based environmental group, issued a report in April naming the Housatonic River as #7 on its list of America’s ten Most Endangered Rivers. HRI nominated the river to bring more attention to the upcoming decision by the USEPA to determine whether more of the river should be cleaned of the PCBs that continue to make the river a toxic waterway.

Download PDF (new window): America’s ten Most Endangered Rivers.

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