As part of its Final Remedy for the Housatonic River Rest of River Site, EPA has opted for landfilling. “Alternative TD 1, disposal in an existing off-site licensed landfill or landfills, would involve the transportation of removed sediment and floodplain soil to commercial solid waste and/or TSCA-licensed landfill(s) for disposal …
“For the preferred sediment/floodplain alternative, the estimated cost of disposal via truck is $308 million and via rail is $287 million.” (GE-Housatonic River, Statement of Basis, Page 25.)
Not surprisingly, GE prefers to landfill PCB-contaminated riverbank soil and river sediments on-site in either “local in-water Confined Disposal Facility/Facilities (CDF)” or “local on-site Upland Disposal Facility or Facilities.”
EPA notes: “Alternative TD 2, disposition in a local in-water Confined Disposal Facility/Facilities (CDF), would involve the placement of dredged sediments in a CDF or CDFs located within the river or backwater area … The estimated cost for this alternative ranges from $100 to $510 million, depending on which Combination Alternative it is paired with; with EPA’s preferred Combination, this alternative is estimated to cost $317 million.
“Alternative TD 3, disposition in a local on-site Upland Disposal Facility or Facilities, would involve the permanent disposition of removed sediment/soil at an Upland Disposal Facility constructed in close proximity to the River, but outside the 500-year floodplain. The removed sediment and soil would be loaded into trucks at the staging areas, covered, and transported over on-site and local roadways to a nearby Upland Disposal Facility.
“Three potential locations for an Upland Disposal Facility were identified and evaluated by GE in the CMS. These sites are located near Woods Pond, Forest Street in Lee, and Rising Pond (referred to, respectively, as the Woods Pond, Forest Street, and Rising Pond Sites). The potential locations evaluated as part of this alternative are shown in Figure 8. The estimated cost for this alternative ranges from $36 to $201 million, depending on which Combination Alternative it is paired with; with EPA’s preferred Combination, this alternative is estimated to cost $100 million.” (GE-Housatonic River, Statement of Basis, Page 25.)
We strenuously object to any remedy/treatment option that moves PCBs from one location to another in Berkshire County. All Berkshire communities adjacent to the River have already paid a price for GE’s environmentally irresponsible behavior. Asking them to host a PCB-disposal facility is asking them to assume yet another unnecessary burden. It is interesting to note from an environmental justice perspective that all three potential locations GE suggests are communities whose median household income is significantly lower than the Massachusetts median household income of $67,846. Median household income in Lenox, MA is $51,201. Median household income in Lee, MA is $59,019. Median household income in Great Barrington is $52,026. Each of these communities faces increasing difficulties to fund local schools and to reduce rising property taxes.
Similarly it is unfair to communities out of state to assume the burden of landfilling PCB-contaminated waste from our community. Especially when there are ways to treat and destroy PCBs.
When it comes to Treatment/Disposal options HRI and the public are at a great disadvantage because EPA has neglected to mandate rigorous pilot studies during the last two decades. We have never been able to effectively evaluate the widest range of alternative remedial technologies that might work in the Rest of River. We are unable to compare the potential ability of bioremediation or other alternative technologies to reduce the quantity and toxicity of PCB-contamination with EPA’s proposed remedy, nor are we able to adequately compare the costs of alternative treatments with the combined costs of dredging and landfilling.
You can study the details of GE’s three proposed dumpsites. Here are the appropriate excerpts from GE’s Revised Corrective Measures Study Report of October 2010, Volume 2, pages 174 – 210: