Housatonic Rest of River — For the second night in a row, Environmental Protection Agency (EPA) officials addressed residents who will be impacted by the Housatonic Rest of River remediation plan, with the October 10 session focused on human health risks from airborne toxins emitted throughout the project’s 13-year-plus tenure. Although the agency’s representatives stated that the inhalation of PCBs pertinent to the project doesn’t put the public at risk according to their criteria, citizens remained vigilant over the safety of the plan.
The issue stems from the deposit by General Electric Company (GE) of the now-banned polychlorinated biphenyl (PCBs) from the company’s Pittsfield manufacturing plant into the waterway for years, with the chemicals washing downstream. A 2020 agreement mandates the materials containing the highest level of PCB concentration be sent out of the area while the lower-level contaminants be deposited into a to-be-created upland disposal facility (UDF) in Lee.
A transportation plan presented by GE last October involves predominantly trucking those dredged materials through southern Berkshire County roads. In June, after much public outcry over the safety of the truck use for transport, the EPA sent GE engineers back to the drawing board to consider using rail as a mode of transportation in the plan, with that update set to be released by October 15.
The Rest of River portion of the project—the last section required to be remediated—spans from the east and west confluence of the Housatonic River at Pittsfield’s Garner State Park through Connecticut into Long Island Sound. The cleanup of that region is expected to start in late 2025 through 2026 with the construction of the landfill in Lee, EPA Project Manager Dean Tagliaferro said. In 2027, river remediation is scheduled for the Pittsfield area and, in 2028, work will center around the Woods Pond area, continuing to about 2040 to complete the entire project, he said.
The evening’s agenda was prompted by a request for the presentation and questions from town officials and the public in general, Tagliaferro said. A copy of the slides presented by the EPA at the meeting can be found here.
Risk assessment: Inhalation of PCBs related to project is not a risk per EPA standards
Diving into how the agency evaluates public-health risks from chemical exposure derived at a Superfund site cleanup, EPA Senior Regional Human Health Risk Assessor Courtney Carroll said the organization first identifies the substances or chemicals (PCBs in the case of the Rest of River remediation) that may cause the health risk. That is done by sampling the materials thought to contain the contaminants. Next, the agency assesses ways individuals could come into contact with the chemicals and how much exposure is possible before it determines how toxic the chemicals are. In the case of PCB exposure, she said the negative health effects from PCB exposure range from neurological issues to immune disorders to cancer. Finally, the EPA looks at the exposure information and toxicity information to determine the risk estimate, or likelihood that negative health effects will result from a site exposure. This risk assessment is required at every Superfund site.
“When we’re talking about cancer risk for exposure to Superfund sites or site-related chemicals, what we’re referring to is the increased risk or the risk that’s in addition to the baseline risk for background factors—and that could be genetics or lifestyle or other factors that contribute to our baseline risk,” Carroll explained.
For the EPA, a cancer risk exists if the disease occurs in more than one in 10,000 people, she said. “For example, if we find that our cancer risk is one in 10,000 people, then this would be considered exceeding our target risk range or cancer risk,” Carroll said.
Risks for non-cancer health issues are determined by comparing the allowable exposure to an estimated amount of exposure at a site, she said.
For the Rest of River site, Tagliaferro identified the consumption of fish and waterfowl as “by far the biggest risk to get PCBs into your system,” followed by prolonged direct contact with contaminated sediment or soil or incidental ingestion. The toxins also pose a risk to certain wildlife species, he said. However, both Tagliaferro and Carroll said that, in addition to certain recreational river activities such as boating or swimming, inhalation of PCBs “was not found to exceed risk criteria.”
Airborne PCBs—what happens if the counts are above safe levels during remediation?
According to Tagliaferro, PCBs can either attach to soil and sediment, becoming airborne when those solids become dusty, or vaporize when the PCB-laden river surface water is dredged. “For current conditions in Rest of the River, airborne PCBs aren’t a threat,” he said, adding that the question has been researched and confirmed by a peer review. “But the situation, the dynamics change when you do a remediation.”
As a result, air monitoring of PCBs and dust monitoring of both the UDF and river/floodplain remediation areas will be conducted, Tagliaferro said. Dust-suppression engineering controls by misting or watering, as well as cleaning and covering or tarping the trucks leaving the work area, are in place, with those actions having been implemented at other Superfund sites including Pittsfield.
Stop-work protocols are also in place, Tagliaferro said. The “trigger” level at the Rest of River site for airborne PCB levels is 0.1 micrograms (mcg), mass per volume, he said, with work halting when testing shows an exceedance of that level. At that point, GE will be prompted to notify EPA representatives of the incident, and those representatives will in turn alert local officials within 24 hours. That .01 mcg trigger level conforms with protocols used by the EPA at the New Bedford Harbor and Hudson River Superfund sites, Tagliaferro said, with the Rest of River level slightly more protective in comparison. “The notification and action levels are set on very conservative assumptions,” he said. “It assumes exposure over an extended period of time for many days, for many years.”
Should the airborne PCB level be above 0.1 mcg, data will be posted on the site’s website within 72 hours of the trigger level, Tagliaferro said. Sampling for airborne PCB levels is conducted for 24 hours, with that sampling occurring prior to work beginning in certain areas as a baseline and at the UDF, he said. Two air samples will be taken for each new area in the first week, with weekly samples following if the testing does not show an exceedance of the trigger level.
Residents voiced concern over the time required to test for airborne PCBs, an average of 14 to 21 days.
“Unfortunately, there is no direct reading instrument, there’s no instantaneous reading of PCBs in air,” Tagliaferro responded. “That method does not exist.”
GE has the primary responsibility to perform the air monitoring, with the EPA conducting its own sampling and using the agency lab to compare with GE’s data, he said.
“The closer you are to the actual work, to where the actual excavators are, to where they’re digging and stockpiling the soil, that’s where the concentrations in the air are, where we expect them to be the highest and dissipate as you get away from the work area,” Tagliaferro said. Therefore, the PCB air monitors will be placed at the perimeter of the site or on or close to public property, he said.
Over the past 25 years of remediation at the Pittsfield site and the first two miles of the Housatonic River, an exceedance of acceptable airborne PCB levels was “extremely rare,” Tagliaferro said. But, when it happened, work stopped, engineering controls such as watering were implemented, and remediation continued only after an acceptable level was recorded, he said.
“Based on this volume of data that was collected in similar situations in areas where there was much higher PCB contamination in the sediment and soil, the data demonstrates that that was done safely and certainly is a strong indication that there shouldn’t be any differences in doing this and the levels will remain open and [within] appropriate guidelines,” Tagliaferro said.
Public response
However, not all attendees, including town officials and area residents, were convinced of the project’s safety.
Lenox Dale’s Robert Davenport questioned the last time the PCB-risk-assessment analysis was updated, with Carroll replying the data was completed in 2005 and has had no updates or modifications to the toxicity guide since. “So, you have 20-year-old data that you’re using for your risk assessment,” Davenport said.
Davenport also pushed for added monitoring on the state-owned October Mountain State Forest that lies adjacent to the UDF site as it is public land.
Charles Cianfarini, interim director for the Citizens for PCB Removal, was skeptical about the height of the PCB air monitors, advocating that wind may force the airborne particles upward. Other commenters inquired as to whether the EPA team was familiar with reports evaluating cancer risks in the Hudson Valley, lower life expectancy in areas surrounding GE plants, and what dams would be affected within the remediation area.
Kaitlyn Pierce, a Pittsfield resident who grew up near the GE plant, relayed her experience illustrating a gap in the awareness of local medical practitioners of the effects of PCB exposure. She correlated her symptoms as a child to some of the listed health issues stemming from in-utero exposure to the toxins and queried the relationship between her children’s health problems and those same effects.
“I actually had a doctor tell me a couple of weeks ago, ‘Well, I don’t know what a PCB is,’” Pierce said to The Berkshire Edge of a local physician. She said her pediatrician had difficulty ordering a blood test that could detect PCBs in the bloodstream.
At the public meeting, Pierce prodded EPA officials for more information on their assurance that PCB-vapor inhalation won’t pose a health risk during the Rest of River cleanup, especially when the soil and sediment in the waterway is disturbed.
“The Human Health and Ecological Risk Assessment conducted in 2003 to 2005 was based on thousands of data samples, including air, sediment, soil, waterfowl,” Tagliaferro said. “That was done. It was peer reviewed by external peer reviews, and those were the conclusions. That’s how we determine if there’s even a need for a cleanup, is there an actionable risk. So, there are peer review, Human Health and Ecological Risk reports that were done, and the two areas where there was risk that was unacceptable by EPA’s national standards were ingestion of fish or fowl and constant and repeated dermal contact or incidental ingestion of floodplain soil. So that’s absent any remediation.”
Pierce countered that the data is almost 20 years old, with no additional consideration since.
“That’s the data we’re using, and GE is collecting additional data now to complete the design,” Tagliaferro responded.
Massachusetts Department of Health weighs in; new cancer study
When Pierce asked about ongoing screening for PCB contamination in humans, Jessica Burkhamer, health assessor with the Massachusetts Department of Public Health (DPH), was on hand to answer her questions. She said DPH has performed outreach to educate local physicians about PCBs, connecting those doctors with other medical personnel who are more experienced in environmental health.
In response to a question posed by Jeffrey Cook focused on local comparisons of PCBs in the bloodstream, she said monitoring for PCB concentrations in blood is “very unusual,” addressing a national survey conducted by the U.S. Center for Disease Control that implemented the testing on a national basis. Burkhamer cautioned that the CDC survey doesn’t break down results to that small of a geographical area.
According to Burkhamer, the department had performed PCB-blood-serum sampling of some staff and students at Pittsfield’s Allendale School, 180 Connecticut Avenue, in 2006. Adjacent to the GE facility and using PCB-laden soil as fill material, the property became contaminated.
“What we found there was that PCBs in blood serum there [were] actually about the same as what we see on a national level and, in some cases, lower,” Burkhamer said. “That testing did not reveal any unusual opportunities for exposure to PCBs.”
At the request of the Pittsfield Health and Safety Committee that has been tracking remediation efforts locally, she said her team is conducting a new study, looking at cancer statistics in Great Barrington, Lee, Lenox, Pittsfield, and Stockbridge. Information on that study can be found here.
The current study follows a 2002 evaluation “that didn’t generally find elevations,” Burkhamer said, with the previous report showing some sporadic elevations of the type expected from researching a broad number of cancer types within a community over a long period of time. The evaluation is now being performed again, she said, reviewing those same five communities, accounting for 10 types of cancers over a 25-year period. “[The Committee] would just like a new look at the cancer data to make sure that nothing is going on,” Burkhamer said.
The current study includes a review of cancer at the town level for those five towns, as well as Pittsfield’s census track.
She said the 10 cancer types were selected based on a series of literature used to find types of cancer somewhat associated with PCB exposure. Bladder cancer was also included because the 2002 study found some elevations in Pittsfield’s statistics in that category even though that type of cancer has not been found to be linked to PCBs, Burkhamer said. “We’ll also take a qualitative look at where these cancer diagnoses are in relation to places of interest, the GE site for example,” she said.
The group is hoping to release that report by the end of 2024.