PCB contamination of the Upper Hudson River. The General Electric Company’s involvement in the pollution will be discussed, as well as the established clean up plans for the largest Superfund site in the country. In addition, current progress on the remediation of the river will be presented.
The Hudson River and PCBs
In the late 1970s, scientists and health officials became aware of the health hazards associated with polychlorinated biphenyls (PCBs). This group of man-made chemicals was used in a variety of industrial processes, from the manufacture of carbonless copy paper to insulators for transformers and capacitors. Due to the unique properties of PCBs, they bind readily to sediment. The sediment sinks to the bottom of rivers and is eaten by small organisms. Through the food chain, and the bioaccumulation process, predators, birds of prey and humans were increasingly exposed to high levels of PCBs. Significant health risks were discovered including: increased incidence of cancer, immunological problems, developmental problems, liver damage, brain disorders, and more.
Prior to their ban in 1976, the General Electric Company (GE) utilized PCBs at two of their facilities along the Hudson River, in New York — the Hudson Falls facility and the Fort Edward facility. Over a thirty-year time span, it is believed that the company dumped up to 1.3 million pounds of PCBs in the river. The 200-mile site, running from Hudson Falls to the Battery in New York City, is the largest Superfund site in the country.
Long years of legal wrangling and lobbying by GE, along with well-placed marketing hoping to garner public support for leaving the site alone, resulted in the organization eventually being tasked with remediation of the site. The remediation program is a three-phase program. The immediate phase and the first of the long-term phase, which involved removal of remnant soil along the river banks that had been exposed due to receding water levels, are complete. The third part of the program, the remediation of the river sediment, is far more complex and costly.
It is anticipated, by the EPA, that this part of the program will cost GE approximately $750 million. Although again the company tried as many stall tactics as possible, work began in the first phase of this sediment remediation. The first phase of the project was a short 6-mile section of the river, which resulted in the removal of approximately 400,000 tons of contaminated sediment. The dredging process was conducted under the watchful eye of the EPA and an outside, independent evaluator. Beginning on May 15th, 2009 and ending October 23rd, 2009, the results from the EPA and the evaluator will be used to fine tune the remediation plan for the remaining 34 miles of the Hudson River, which is scheduled to begin in 2011.
The costs of this remediation project go beyond those of this current remediation of the river sediment. In addition to removal and capping costs already incurred, GE faces possible additional clean up projects in the near future. Testing in the floodplains has recently been conducted and GE may be looking at more remediation work in these areas. What seemed to be a cost effective business strategy of disposing GE’s PCB waste into the river will now likely cost the organization more than $1 billion, once it’s all said and done.
PCBs Overview and Their Effects
Polychlorinated biphenyls (PCBs) are a group of man-made chemicals that were used commonly in electrical equipment. They were also widely used in a variety of industrial processes and during manufacturing and recycling of carbonless copy paper. PCBs were used until research found the chemicals posed human health risks, as well as risks to wildlife and the environment. In 1976, the production of PCBs was banned, in the United States. However, PCB contamination is still an environmental concern due to the improper disposal of products that contained PCBs, as well as disposal of byproducts that were used in the process of making these products (“What are PCBs,” 2008). Of particular challenge are the binding properties of PCBs and its effect on the food chain.
PCBs do not dissolve readily in water; however, they do bind easily with sediment particles. The Wisconsin Department of Natural Resources (“What are PCBs,” 2008) notes that the binding of PCBs to sediment particles is one million times stronger than to water molecules. Once PCBs attach to sediment, they eventually sink to the bottom of the water source. There, tiny organism eat the PCB-laden sediment particles. Small fish eat these organisms and retain the PCBs in their body fat. Small fish are eaten by larger fish. Larger fish are eaten by birds of prey and people. Due to bioaccumulation and biomagnification, PCB levels is humans, birds of prey, and larger fish can be millions of times higher than found in surface water. There are several serious health concerns associated with the build up of PCBs in the body.
The public health implications of PCBs is significant. Stored in fat, PCB levels can increase over time. Human health concerns include immunological, developmental, reproductive, and neurobehavioral problems. Studies found several serious health concerns due to exposure to PCBs. PCB exposure was found to be linked to an increased risk of cancer. Infants and children born to mothers who were exposed to PCBs demonstrated increased developmental problems and reduced mental abilities. Nervous, immune, circulatory, and hormonal system problems were more prevalent in those who had been exposed to PCBs. Liver damage, brain disorders and skin problems too were found to be associated with PCBs (“PCBs and health,” 2008). Because of the physical properties of the chemicals, the greatest exposure risk comes from consumption of fish.
The most common way humans come into contact with PCB-contaminated sediment, is through fish. The highest incidence of exposure is found in people who are recreational anglers and high-intake fish consumers. These two groups were found to have the highest cancer risks and non-cancer health effects, due to their large percentage of PCB-laden fish consumption. In fact, the risk of harmful effects is 10 times higher, for fish consumers, than any other group (“PCBs and health,” 2008). According to the EPA, exposure pathways other than fish consumption, do not pose a significant risk, including: drinking water, volatilization, and recreational exposure to contaminated settlement or water (“Hudson River PCBs,” 2008). Although PCB contamination can be found across the United States, one of the most highly publicized contamination sites is the Hudson River, in New York.
The Hudson River Site
Deemed an American Heritage River, due to its important role in American history and culture, the Hudson River is one of the most well-known PCB contamination sites. The Hudson River PCBs site runs approximately 200 miles from Hudson Falls, New York to the Battery in New York City. One of the most highly contaminated areas of the site, and the area first chosen for remediation, is the 40-mile stretch reaching from Hudson Falls to Troy, New York, as the river traverses through Washington, Saratoga, and Rensselaer Counties. Two capacitor manufacturing facilities, owned by the General Electric Company, had been located in Hudson Falls and Fort Edward, New York. PCBs discharged from these two plants contaminated the Upper Hudson River. Five remnant deposits were also included in the first area of remediation, following their exposure due to the lowering of the level of the river, when the Fort Edward dam was removed in 1973 (“Hudson River PCBs,” 2008). The PCB concern originally led to a ban in fishing.
Bioaccumulation of PCBs in fish and other aquatic organisms led to a ban by the State of New York of fishing in the Upper Hudson River, in 1976. It wasn’t until 1995 when this fishing was reopened on a catch-and-release basis, while the lower Hudson River still has a commercial fishing ban in place, along with a consumption advisory (“Hudson River PCBs,” 2008). Although consumption of contaminated fish is a primary means of transfer of the toxins, maternal transfer too can occur.
Kelly, Eisenreich, Baker, and Rowe (2008) studied the accumulation and maternal transfer of PCBs in snapping turtles. It was found that the PCB contamination of the Hudson River had significant negative effects on the snapping turtles. The researchers collected adult turtles in areas known to be contaminated with PCBs. They also analyzed PCB levels in eggs in the area. Both adults and eggs were found to have high levels of PCBs, resulting in the conclusion that there was maternal transfer to the eggs. In addition, there are several other environmental, economic, and social factors of concern for this Hudson River area.
The state capital city of Albany lies in the Hudson River Basin. Much of the land in the basin is used for agricultural purposes, as well as service, manufacturing and residential. The Hudson River is a primary source of hydroelectric power for the area. There is transportation that relies on the river as well. Recreation on the Hudson River is an aspect that needs to be taken into consideration as well. Additionally, the water intake near Chelsea may be used, at times, to supplement New York City’s water supply, during times of drought. The Town of Waterford and the Town of Halfmoon both get their muncipal water supply from the Upper Hudson River (“Hudson River PCBs,” 2008).
GE’s Involvement in the Build Up of PCBs in the Hudson River
From 1947 to 1977, the General Electric Company discharged as much as 1.3 million pounds of PCBs into the Hudson River, polluting 197 miles of the river and creating America’s largest Superfund site. Two of GE’s facilities, one at Hudson Falls and one at Fort Edward are reported to be the source of the pollution. As Angelo (2009) notes, PCBs were used as high-temperature insulators in the manufacturing process of transformers and capacitors, at the GE facilities. Even today, more than three decades later, PCBs still leak into the river from GE’s facilities. According to Superfun law, polluters are charged with cleaning up the pollution they’ve created; however, GE has continued to fight the development of a cleanup plan. The organization has lobbied Congress, attacked the Superfund law in court and launched a media campaign stating that the proposed dredging of the river would stir up the PCBs (“Historic Hudson,” 2007). However, remediation of the site was slated to commence.
In 2002, the EPA’s decision against GE was the catalyst for the organization’s plan to remove 800 Olympic swimming pools worth of contaminated river sediment. However, the company procrastinated for nearly four years. The remediation project was scheduled to begin in October 2005, but did not start until 2009 (“Historic Hudson,” 2007). While GE instigated protracted legal battles, the contamination continued, moving downriver and spreading the contamination further.
Clean Up Approach
Clean up of the contaminated site of the Hudson River is being addressed in three stages. The first are immediate actions, followed by two long-term remedial phases involving remnant deposits and river sediments. The immediate actions of the clean up approach occurred in 1977 and 1978. At this time, an estimated 180,000 cubic yards of contaminated river sediment were dredged from the east channel of the Hudson River, at Fort Edward, in an effort to clear the navigational channel. These 180,000 cubic yards of sediment, along with approximately 14,000 cubic yards of highly contaminated sediments from a remnant area, were placed in a clay-lined containment cell (“Hudson River PCBs,” 2008).
Investigators at Bakers Falls, near the GE Hudson Falls facility, found elevated PCB concentrations in the water column, in 1991. At that time, GE signed a consent agreement allowing the State of New York to further investigate, as well as to take interim remedial measures in order to prevent PCB contamination from the site to enter the river and additional immediate actions were taken. The company took a variety of measures to help prevent contamination of the Hudson River. These included: the prevention of river water flow through seep areas and a mill building that had been abandoned, seep collection system installation, contaminated sediment was removed from the mill building, areas where seeps were found in the riverbed were pressure grouted, and PCB collection wells were oiled (“Hudson River PCBs,” 2008).
In the early 1990s, removal of contaminated soils was performed on Rogers Island. Concerns had arisen that the exposure to PCBs by current residents and possible future users of Rogers Island, would be a risk to the public’s health. Therefore, the EPA decided to remove the PCB contaminated soils from the northern part of the island, where the residential section was located. This removal was completed by December 1999. In March 2004, the State of New York selected a long-term remedy for the GE facility (“Hudson River PCBs,” 2008).
The first long-term remedial phase centers on remnant deposits. GE did conduct an interim clean up of the remnant deposits, per a Consent Decree with the EPA, as selected in the 1984 Record of Decision for the site. The method of remediation chosen for this phase was in-place containment of the remnant deposits located on the shoreline. As mentioned, these remnant deposits were exposed with the lowering of the river level due to the removal of the Fort Edward dam. The process for this remediation included covering the affected area with a geosynthetic clay liner, along with a 2-foot layer of soil. This was then followed with grading and revegetation, as a means of minimizing erosion. Rocks were utilized to stabilize river banks to prevent scouring. By 1991, the capping of the area was completed and gates had been erected to limit site access (“Hudson River PCBs,” 2008). The actual removal of sediments in the river itself would not see a plan formed for more than a decade.
Finally, in February 2002, the EPA decided that it was appropriate to remediate the Upper Hudson River and the contaminated sediments. The remediation selected includes dredging approximately 2.65 million cubic yards of PCB-contaminated sediments out of the Upper Hudson River. The EPA estimated that there would be approximately 150,000 lbs of PCBs in this removed sediment — approximately 65% of the total PCB mass they believed to be present in the Upper Hudson River. Of course successful remediation also depended on separate source control action taken at the GE Hudson Falls plant to prevent new contamination from occurring (“Hudson River PCBs,” 2008). There are several primary components to this plan.
The river sediments removal project is a much more involved plan. There are several components that have to be performed for the project to be successful. First, river sediments in River Section 1, River Section 2 and River Section 3 must be removed. The navigation channel must be dredged as necessary to facilitate remediation and prevent hindering of canal traffic during remediation, Air quality and noise performance standards must be monitored and kept in accordance with state and federal law. Independent external peer review of the project must be conducted and evaluated at the end of the first phase of dredging. Dredged areas must be backfilled with at least one foot of clean material, in order to isolate the residual PCB contamination, as well as a means of expediting habitat recovery. The dredging techniques utilized must be environmentally efficient, in order to minimize the resuspension of sediments during dredging. Dredged sediments will need to be transported via barge or pipeline to processing and transfer facilities, to be dewatered and stabilized. Once the contaminated sediment is dewatered and stabilized, it will have to be transported to an appropriate, licensed, off-site landfill for disposal. Fish, water and sediment will have to be monitored to determine if the remediation goals are reached. Restoration of aquatic vegetation will also need to be monitored. Institutional controls, such as fishing restrictions and fish consumption advisories, will need to be implemented and/or modified as necessary until remediation goals are met (“Hudson River PCBs,” 2008). The clean up process for this phase begins with remedial dredging in two phases.
The first phase of dredging is to be conducted at less than full scale operation. Extensive monitoring of all operations will be included in this phase. In addition, an independent, external peer review of the dredging resuspension, PCB residuals, and performance standards of the production rate will be conducted. With this information, Phase 2 can be modified to improve the results. Phase 2 will include the remaining dredging of the project and will be conducted at full-scale. The EPA will continue to monitor the project and evaluate performance data, in order to make adjustments (“Hudson River PCBs,” 2008). Floodplains are also a concern of the project.
Sampling of the floodplains of the Hudson River have been initiated. The initial sample phase resulted in several floodplain areas being targeted for removal action. This removal was performed, in 2007, by GE (“Hudson River PCBs,” 2008). The legal battles and planning have been a long, drawn out process; however, finally some progress has been made on the major components of remediation for the Upper Hudson River.
Progress to Date
As Angelo (2009) notes, it has been thirty-two years since the last PCBs were discharged into the Hudson River, from GE’s manufacturing complexes. After decades of legal wrangling, on May 15th, 2009, GE began the third, and most costly, phase of the remediation project. The removal of the first 400,000 tons of contaminated sediment, along a six-mile stretch of the Hudson River, near Fort Edward, began this spring. The additional dredging of the 34-mile stretch of the river to Troy will be in the second phase of dredging.
Although GE has not released the costs for the project, the EPA has estimated clean up to reach approximately $750 million. Because the PCBs tend to accumulate in the slow-moving portions of the rivers, such as at bends and turns, dredging will be targeted at these spots, according to Angelo (2009). A bevy of equipment was brought on site in order to facilitate the remediation.
Twelve barge-mounted excavators, 18 tugboats and 37 barges were utilized to remove the 400,000 tons of toxin laden sediment (Sawyers, 2009). The 12 barges used clamshell buckets and were guided by a global-positioning system. The sediment was then loaded onto barges and shipped off to a nearby 110-acre processing plant for dewatering and stabilization. The processing plant also separate debris and removed grit and sand. The water removed from the sediment was processed to drinking water standards and then discharged back into the river. The final dried sediment was then shipped by rail to a hazardous waste disposal facility in Andrews, Texas (Angelo, 2009). Sawyer describes the procedure for disposing of the contaminated cakes of sediment. He notes that the landfill uses layers of mesh, clay and plastics, in order to isolate the contaminated sediment from the surrounding Texas soil, as well as the water below the burial site and the air above it. As noted in the clean up approach, this was Phase 1 of the two-phase dredging operation.
Rigorous standards had to be met. Angelo (2009) cites a production standard of 5,000 cu yd per day, with dredging depths ranging from 3 inches to 9 feet. In addition, PCB suspension levels could not be more than 500 parts per trillion. Residual levels could be no more than .25 parts per million. Dredging for Phase 1 was conducted 24 hours per day, six days per week. The seventh day was reserved for maintenance and to make up any time that had been lost due to unplanned project interruptions. Phase 1 dredging lasted 133 days, from May 15th through October 26th, 2009. Backfilling and capping in certain areas continued through November, until the Champlain Canal closed for the season (“First phase,” 2009). In addition to the dredging operation, a tunnel and drain project was recently completed as well.
Beginning in late 2007, a joint venture of Merco Inc. And Obavashi Corp. began a tunnel ad drain complex. This series of 4-inch diameter drains, running under the river near GE’s Hudson Falls site, channel PCBs leaking through the bedrock into two 1,000-foot long, Y-shaped, 10-foot diameter tunnels. The PCBs will then be pumped to a wastewater treatment plant, where the water will be treated and discharge back into the river. The contaminated oil from the water treatment process will be shipped to a licensed disposal facility in Port Arthur, Texas (Angelo, 2009). The second phase of the dredging remediation is to begin in 2011 (Angelo, 2008).
Other Costs to GE for the Clean Up of the Hudson River
Enforcement of the remediation project is facilitated by two Administrative Orders on Consent, with GE. Under the agreements, the EPA has already received approximately $37 million, for past site costs, from GE. The Consent Decree instructs GE to pay the EPA an additional $78 million, for the EPA’s past and future costs. Understanding that GE, in the past, has drug its heels with this project, the agreement does include a provision that ensures no is delaying the transition between Phase 1 and Phase2 . With this provision, GE must spend up to $5 million, between the end of Phase 1 and the date of whether or not GE would like to conduct Phase 2. If GE decides not to take on Phase 2 of the sediment remediation project, it must reimburse the EPA for any costs it incurs and pays using government funds. In 2007, GE signed another Administrative Order on Consent (AOC) centering on a floodplains removal. In September 2008, the company entered into an AOC to conduct additional investigation in the floodplains. All of these costs are in addition to the remediation work, of the Phase 2 sediment removal project.
It took until the late 1970s for the United States to realize the carcinogenic, as well as other, health hazards of the use of PCBs. PCBs were a popular manufacturing material, used in a variety of manufacturing processes and products. However, it was determined that there were numerous, sometimes fatal, health concerns for the public. As such, in 1976, the manufacture of PCBs was prohibited in the United States.
By the time of the ban, GE had already been using PCBs in the manufacture of their transformers and capacitors for three decades. Two of their facilities, located at Hudson Falls, New York and Fort Edward, New York, had been dumping PCBs into the Upper Hudson River since 1947. The result was approximately 1.3 million pounds of PCBs being discharged into the river.
Because of the PCBs ability to so easily bond with sediment, these PCBs would bind with sediment floating in the water and then, at slow parts of the river, would settle to the bottom. Small organisms would consume the tainted sediment and then be eaten by small fish. Small fish would be eaten by big fish, and through bioaccumulation, large amounts of PCBs would be stored in the fatty tissue of larger fish that were being consumed by predators, birds of prey and humans. For this reason, a ban on fishing in the Hudson River was implemented and a public warning against the consumption of fish was issued. While PCB exposure was most often instigated by fish consumption, passing of PCBs maternally was also found to be happening, as found in the high levels of PCBs in the eggs of snapping turtles.
The EPA determined the 200-mile section of the Hudson River was in need of remediation, making it the largest Superfund site in the United States. GE sought every legal avenue possible in order to prevent their paying for the clean up. However, in the end, they were given a three-pronged clean up plan. Immediate remediation was conducted quite quickly. The second prong, which involved the remediation of he remnant PCB soil that was exposed when river levels lowered, due to the removal of the Fort Edward dam, also occurred expeditiously, with the removal of contaminated soil and the capping of the area, as well as gating it off to restrict access. It was the third -most expensive — prong that had GE dragging its corporate heels.
This prong involved a two-phase plan for dredging the contaminated sediment from the bottom of the river.
On May 15th, 2009, dredging of the Upper Hudson River began. The first phase of this remediation project was only a small portion of the entire project. This first phase was used to monitor production levels, resuspension levels, and a variety of other factors, in order to ensure that the task is being completed efficiently, effectively, and safely. A multitude of equipment was brought out to the Phase 1 site.
Approximately 400,000 tons of PCB-taineted sediment was dredged up, placed on barges, and taken to a processing plant. There the sediment was dewatered and stabilized. The water from the dewatering process was transferred to a wastewater treatment plant. There the water was treated to drinking water standards and then discharged back into the river. The stabilized, contaminated cake of sediment was shipped to Texas. There it was wrapped in mesh, clay and plastics, in order to prevent any of the PCBs from leeching into the surrounding soil, water table or air.
In addition to this dredging operation, a series of tunnels were dug under the river to collect PCB-laden water that leaked through the bedrock. Again, this water is pumped up into a wastewater treatment facility. The water is purified to drinking water status before being released back into the Hudson River. The oil, with the PCB contaminants, is then shipped to another waste disposal facility in Texas.
Although for thirty years GE had made a decision to dispose of their PCB waste by simply dumping it into the historic Hudson River, hindsight shows that this was not the best business decision to make. Without considering the moral implications of polluting a valuable resource, and the ecological and effects on humans this had, looking at the costs incurred post-pollution should be a wake up call for not only GE but other organizations as well. What seemed to be an easy, inexpensive method of disposal for manufacturing waste, by discharging it into the river, will now cost the organization more than $1 billion, when all of the remediation efforts over the years has been added up. If GE wants to continue to ‘bring good things to life’, they have to protect the life that is already here.
Angelo, W. (25 Feb 2008) Hudson River PCB cleanup projects under construction. Engineering News Record, 260(7). Retrieved December 9, 2009, from Academic Search Complete database.
(1 Jun 2009). PCB remediation work starts in the Hudson River. Engineering News Record, 262(17). Retrieved December 9, 2009, from Academic Search Complete database.
Historic Hudson River cleanup to begin after years of delay, but will General Electric finish the job? (23 Mar 2007). Retrieved December 9, 2009, from http://www.nrdc.org/water/pollution/hhudson.asp.
Hudson River PCBs. (31 Dec 2008). Retrieved December 9, 2009, from http://www.epa.gov/region02/superfund/npl/0202229c.pdf.
Kelly, S., Eisenreich, K. Baker, J., & Rowe, C. (Dec 2008). Accumulation and maternal transfer of polychlorinated biphenyls in snapping turtles of the Upper Hudson River, New York, USA. Environment Toxicology & Chemistry, 27(12). Retrieved December 9, 2009, from Academic Search Complete database.
PCBs and health — Fish consumption advisory. (1 Oct 2008). Retrieved December 9, 2009, from http://www.dnr.state.wi.us/org/water/wm/foxriver/health.html.
Sawyers, H. (Oct 2009). Dredge it up, ship it out. Popular Mechanics, 186(10). Retrieved December 9, 2009, from Academic Search Complete database.
What are PCBs? (1 Oct 2008). Retrieved December 9, 2009, from http://www.dnr.state.wi.us/ORG/water/wm/foxriver/whatarepcbs.html.
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