TREATMENT
By Mickey Friedman
December 2018

If there’s something more dangerous than PCBs, it’s dioxin. It’s about 8,000 miles from EPA Region 1 headquarters in Boston to the Danang air base in Vietnam. I wish it was closer because the Vietnamese and the U.S. Agency for International Development (USAID) figured out a solution to our PCB problem here in the Berkshires.

Years of advocacy forced General Electric to clean hundreds of PCB-contaminated backyards, a schoolyard, a children’s park and the first two miles of the Housatonic River.

Now, in order to save $250 million in transportation costs, GE wants to put the contaminated soils and sediments from the cleanup of the rest of the Housatonic River in convenient local PCB dumps. Residents, understandably, want the highly-toxic contaminated material shipped out-of-town.

GE knows about big dumps because in 2000 the EPA allowed them to move the contamination from the first two-mile cleanup in Pittsfield into two dumps across from the Allendale elementary school.

Last week EPA held yet another public meeting to talk about its ongoing negotiations about the river cleanup. According to the Berkshire Eagle, Tim Conway, an attorney for EPA Region One stated they’re engaged in mediation to see if a new approach exists. “A solution that everyone can agree with that would lead to a faster and better cleanup,” Conway said.

After 30 years of meetings and ten years spent making the documentary film “Good Things To Life: GE, PCBs and Our Town,” I couldn’t make myself go. I know EPA is unwilling to push for the one solution that would avoid both local dumps and trucking contaminated sediment to someone’s else backyard: TREATMENT.

Why dioxin and Danang? Because on November 8, 2018, USAID announced “the completion of the environmental remediation of dioxin (Agent Orange) at Danang Airport … a historic, six-year, $110-million project between the United States and Vietnam … The recently completed second phase of treatment has produced excellent results with residual contaminants in the treated soil measuring less than 1 part per trillion (ppt), well below the treatment goal of 150 ppt. In the next 2 months, approximately 90,000 cubic meters of treated soil will be returned to general use as common fill for airport expansion.”

Why do I believe this applies to us? Because they first carried out a comprehensive Environmental Assessment “and evaluated a number of possible dioxin remediation technologies. Thermal desorption treatment was determined to be the most effective and scientifically proven method for destroying dioxin and to have the lowest potential impact on human health and the environment …”

How does it work? “The excavated soil and sediment is placed into a completely enclosed above-ground pile structure. Heating rods operating at temperatures of approximately 750 to 800 degrees Celsius (°C) (1400 to 1500 degrees Fahrenheit [°F]) raise the temperature of the entire pile to at least 335°C (635°F). At that temperature, the molecular bonds holding the dioxin compound together break, causing the dioxin compound to decompose into other, harmless substances, primarily CO2, H2O and Cl2.”

The treatment containment structure is far smaller than GE’s planned dumps. At Danang Airport it was 229 feet wide and 328 feet long. Over several years they successfully and safely treated up to 95,000 cubic meters of dioxin-contaminated material.

Read more here: https://www.usaid.gov/vietnam/environmental-remediation-process.

EPA rejected Thermal Desorption for the rest of the river. Their estimated cost was between $515 and $540 million. But their estimated cost for transporting all the contamination sediment and soil to an off-site dump was $308 million by truck, or $287 million by rail. Do you think GE can afford an additional $200 million to avoid a ten year long legal battle and PR nightmare and do right by the people of Berkshire County?

I made the case for Thermal Desorption in the Housatonic River Initiative’s appeal of EPA’s cleanup plan before the Environmental Appeals Board. Region One responded first with a technicality: “HRI’s Petition repeatedly raises arguments that HRI did not raise in its 2014 comments, such as the CERCLA preference for treatment… and HRI’s preference for thermal desorption … As such, in accordance with 40 C.F.R. §124.19(a)(4)(ii), those arguments should not prevail.” Yes, HRI forgot to specifically mention thermal desorption in its 2014 comments to EPA, but we have referenced thermal desorption for more than two decades in countless public meetings and official filings.

Secondarily, EPA declared: “High costs, uncertain effectiveness, and/or community preferences (for on-site operations) are factors that lead to treatment being selected infrequently at sediment sites.” The [2005 Contaminated Sediment Guidance] goes on to state that “. . . the practicability of treatment, and whether a treatment alternative should be selected, should be evaluated against the NCP’s nine remedy selection criteria. Based on available technology, treatment is not considered practicable at most sediment sites.”

Vietnam and USAID found that Thermal Desorption gave them the better cleanup they deserved. How about us?

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Treatment was published in the December 20, 2018 issue of The Berkshire Record.

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HRI EAB APPEAL

THE HOUSATONIC RIVER INITIATIVE (INC) EAB APPEAL OF EPA DECISION FOR THE CLEANUP OF THE REST OF THE HOUSATONIC RIVER

The Housatonic River Initiative has lodged an official appeal of the United States Environmental Protection Agency’s (EPA) Final Remedy for the cleanup of the Rest of the Housatonic River with the EPA’s Environmental Appeals Board in Washington DC. (The United States et al. v General Electric, Appeal from Permit Decision. Docket No. MAD002084093. Statute: Resource Conservation and Recovery Act.)

Here is a PDF file of the entire appeal including two attachments: A Short History of HRI and a copy of citizen’s petition challenging the General Electric Company’s desire to site up to three large PCB-dumps in the Berkshires: one in Lenox, MA, one in Lee, MA, and a third in Housatonic, MA.

HRI EAB BRIEF

Here is a PDF of just the first Attachment: A Short History of the Housatonic River Initiative (Inc.): Fighting for a Fishable, Swimmable Housatonic

A SHORT HISTORY OF HRI

HRI Press Release regarding the decision to Appeal the EPA Final Remedy for the Rest of the Housatonic River

HRI EAB PR

On February 14, 2017 Region 1 issued a response seeking to disqualify HRI’s petition before the Environmental Appeals Board. You can download the PDF by using the link below:

HRI Response Brief_RCRA 16-02

HRI responded in some detail to the reasons – some about our failure to follow EPA process and some about technical differences – that Region 1 argued before EAB. You can download our Reply to Region 1 by clicking the link below:

EAB HRI REPLY TO REGION 1(1) 03.24.17