Housatonic Rest of River — In separate conditional approval letters dated September 12, the U.S. Environmental Protection Agency (EPA) responded to General Electric Company’s (GE’s) proposed Upland Disposal Facility (UDF) Final Design Plan and UDF Operation, Monitoring, and Maintenance (OMM) Plan, offering only a partial acceptance of the conglomerate’s submissions regarding the Housatonic Rest of River remediation plan.
GE has until December 20 to resubmit its revisions to these plans, with the public allowed to weigh in on that resubmission through February 3 of next year.
The documents stem from a 2020 agreement between the EPA, GE, and five towns—Great Barrington, Lee, Lenox, Sheffield, and Stockbridge—that resulted in a remediation plan for the Housatonic River following decades of GE depositing the now-banned polychlorinated biphenyls (PCBs) into the waterway. That agreement provided for the most toxic materials dredged from the river to be taken out of the area, leaving the lower-PCB-concentrated materials to be stored in a UDF, or landfill, in Lee. The town’s residents, now joined by neighboring communities, have long opposed the provisions, citing safety and environmental concerns regarding the site, as well as the proposed transportation route to cart the dredged toxic materials through southern Berkshire County.
Understanding the UDF system proposed by GE
An April 18 information session conducted by the EPA highlighted the proposed UDF system that will accommodate up to 1.3 million cubic yards of material within a 20-acre section of the Lee tract. The UDF system will be dug out, built up to a maximum of 1,099 feet above sea level, and sloped. The current ground level at the UDF site is 1,030 feet to 1,050 feet above mean sea level. Renderings illustrating the height of the proposed UDF were released by the EPA on May 6.
The facility’s bottom liner is proposed to be at least 15 feet above the estimated seasonal-high level of the groundwater, or aquifer, and its baseliner will contain individual liners: a layer of clay placed above the subgrade soil; a geosynthetic clay liner; a 60-milliliter low permeability, high density polyethylene (HDPE) layer made from petroleum; a drainage layer to collect leachate, or liquid formed when rainwater filters through wastes in a landfill; another geosynthetic clay liner; another 60-milliliter HDPE liner; another drainage layer; and an aggregate layer for machinery to drive on.
The leachate will be collected in tanks before being shipped to either GE’s Pittsfield campus or to an off-site facility for treatment. The plan includes later constructing an on-site leachate-treatment system.
Highlights of EPA’s response to the UDF Final Design, OMM plans
In a September 16 email, the EPA outlined the new steps the agency is requiring of GE in its UDF design. That response can be found here.
Specifically, the agency is looking to GE to now provide additional assurance on the safety of the HDPE liner, that the product is compatible or safe to come in contact with PCBs, and offer a monitoring plan that will ensure the liner system’s integrity. Residents have previously expressed concern at public meetings whether the liner will be able to stand up to this system without leaking toxic materials.
The EPA is requiring GE to provide added specificity regarding its leachate-treatment system, including the system’s designs and locations, backup-power sources, and a more detailed decontamination plan to prevent the spread of contaminated materials from the site.
The agency is now requiring GE to create a second access road to the UDF property from the lower part of Willow Hill Road “that will result in the least distance travelled up Willow Hill Road from Mill Street.” This new road will also help the transportation trucks avoid passing homes or the October Mountain campground entrance.
The EPA’s response addresses questions concerning the possible degradation of the UDF system slope, requiring more specifications of its stability in addition to liner strength, especially if significant rainfall occurs. The agency is also requiring additional information that will add to the protection of the site’s vernal pools, as well as that GE produce a revised greenhouse-gas evaluation.
According to the EPA email, GE’s resubmission of its proposed UDF OMM must now include information on what practices it will use to decontaminate construction equipment used on the UDF before those items, including trucks and truck tires that may harbor toxic soil and sediment, leave the site. That response can be found here.
As with the UDF Final Design, the EPA is requiring GE to refocus on the operation and monitoring of its leachate-collection system with greater detail.
The agency eyed GE’s proposed reporting requirements. As opposed to the company providing operation and maintenance reports annually to the EPA, GE will now be required to hand in those documents every six months, or twice a year. Regular air-monitoring updates by GE will be required to be posted for the public on its website. Added monitoring requirements now include GE conducting up to four rounds of baseline air monitoring before UDF operations begin, groundwater sampling every six months as opposed to annually, and stormwater-infrastructure sampling.
The EPA cited public input it received in response to the two GE proposals but didn’t incorporate into its response, including concerns over how climate change will affect the UDF plan. During its April session, Lee PCB Advisory Committee member Robert Heinzman questioned the role of the 100-year flood plain in the UDF design given that those benchmarks have been declining due to climate change, with stronger and more frequent rainstorms occurring. In its email, the EPA stated the Final Design Plan has already considered climate change and the impact of more severe storms on the UDF design. The agency reasoned that the UDF location “is well above the floodplain of the Housatonic River such that flooding from the River will not be an issue.” Should an overflow of noncontact water from the plan’s stormwater basins occur, that water will flow to where it naturally flows now, before the UDF is built, and “not cause any increased erosion or flow concerns.” Any contact water would fall into the UDF’s leachate system.
Berkshire residents have also expressed skepticism that the UDF bottom layer is high enough over an existing aquifer so as to not interfere with the groundwater. In April Matthew Calacone, GE-Aerospace senior project manager for the UDF, stated that the bottom liner will be at least 15 feet above the estimated seasonal-high level of the groundwater, with the design providing an extra foot—16 feet of separation—between the bottom of the liner and the groundwater estimate. According to Calacone, the dredged material will be more than 22 feet away from the estimated seasonal-high groundwater level.
In its email, the EPA stated the relative groundwater elevation wasn’t addressed in its response because its calculation of seasonal-high groundwater uses 37 years of historical data and the minimum distance between the seasonal-high groundwater level and bottom of the liner layers is greater than what is required by both the 2020 permit and the Massachusetts Department of Environmental Protection landfill regulations. “The UDF’s design standard of at least 15 feet of separation is so conservative that there is no foreseeable scenario in which the groundwater level could rise to make contact with the consolidated material,” the email states.
Finally, residents and local and state officials have decried the use of trucks as the sole mode of transporting the dredged materials to the UDF. Although GE was sent back to the drawing board by the EPA to draft a thorough consideration of rail for that transportation measure after submitting its transportation proposal, the agency declined in its current response to incorporate a rail-based offloading area at the UDF. It cited “elevation grades and space constraints” as reasons the measure was “not likely feasible.” “Materials transported by rail destined for the UDF and off-loaded near the UDF would not entail changes to the UDF design,” the EPA email stated.
Upcoming meetings related to the Housatonic Rest of River cleanup
The EPA is holding a meeting of the Citizens Coordinating Council on October 9, from 6:30 to 8 p.m., in the Lenox Memorial Middle and High School Library, 197 East Street, Lenox.
On October 10, from 6:30 to 8 p.m., the EPA is scheduled to provide a presentation on airborne PCBs at the Lee Middle and High School Auditorium, 300 Greylock Street, Lee.
