Berkshire County — Although General Electric Company’s recent release details measures aimed at diminishing the negative impacts of a multi-decade remediation process, some say its December 20 Quality of Life Compliance Plan — a plan that assumes the trucking of toxic materials to a local dump site or out of the area — is flawed by not, at least, providing a rail option in its proposal.
GE was required to publish the plan pursuant to a 2020 permit covering the remediation of the Housatonic River following the company depositing the now-banned polychlorinated biphenyls (PCBs) into the waterway for years. The permit—signed by then-representatives of Great Barrington, Lee, Lenox, Sheffield, and Stockbridge, as well as representatives from GE and the Environmental Protection Agency—stipulates that the most toxic materials will be carried out of the area while the less contaminated sediment will be taken to a to-be-constructed Upland Disposal Facility (UDF) in Lee.
Since the October 31 release of GE’s Proposed Transportation and Disposal plan that heavily favored trucking as the transport method for the Rest of River, the third segment of the Housatonic River to be remediated, there has been an outcry from citizens and officials in the five affected towns to consider rail as a transportation option to both the UDF and out of the area or, in the alternative, to simply remove the dredged materials to an already established UDF elsewhere. Lee stakeholders have long objected to the plan that puts the UDF in their backyard. The town of West Stockbridge joined that fight on January 16 as its Select Board signed on to a letter, along with the five original towns, addressed to the EPA and supporting the rail option.
EPA spokesperson Jo Anne Kittrell told The Berkshire Edge that the Quality of Life Plan meets the requirement outlined in the 2020 permit and that the “EPA is in the beginning phases of reviewing the document.”
The plan
Applicable to Reaches 5A through 8 of the permit, from Pittsfield through Rising Pond Dam (see attached map), the plan outlines steps GE will take to minimize potential negative impacts from the project on local air quality, noise, odor, lighting, recreational activities, transportation, and roads, as well as communication strategies to keep residents informed. These stated efforts include coordinating “more meetings similar to the [November 28] Transportation Plan meeting,” which was held with representatives from GE, GE contractor Arcadis, the Environmental Protection Agency, and Lee officials.
The plan acknowledges that PCBs can be sent into the air and moved by air currents, with GE proposing the implementation of an air monitoring system at a minimum of three points complemented by assembling meteorological stations at the Pittsfield GE facility, the UDF, and a site near Rising Pond to record wind speed and direction. According to the plan, if certain acceptable levels of air particle emission are exceeded, GE must notify the EPA of the issue, possibly mitigating the breach by spraying materials and unpaved truck hauling routes with water; adding a cover or sprayed foam over exposed materials; providing wind screens; putting on covers to off-road truck beds; and monitoring more often and at additional sites.
With the possibility of overnight hours of construction, the plan cites an acceptable maximum level of residential daytime noise at an hourly average of 80 decibels from 7 a.m. to 9 p.m. and 65 decibels from 9 p.m. to 7 a.m. In commercial or non-residential areas, 80 decibels is the maximum hourly average limit for both daytime and nighttime. For perspective, an 80-decibel sound is equivalent to a lawnmower’s minimum sound; normal conversation is 60 to 70 decibels; and an emergency siren clocks in at 110 to 129 decibels, according to the National Institute on Deafness and Other Communication Disorders. According to the plan, GE will use a sound-level meter run for one hour every four hours during the construction day to monitor project noise, adding shrouds, barriers, sound walls, noise mufflers, and quieter equipment backup alarms if needed. The operational speed of the equipment can also be lowered, and equipment routes changed.
Although PCBs don’t have an odor, the decaying plants and greens dredged during the remediation process do, the plan states, with GE to take remediation action if the odor is the subject of repeated complaints or if it is an “uncomfortable” or persistent odor. Should lighting complaints become frequent, recurring, or not taken care of in a timely manner, GE is charged with taking responsive measures such as redirecting the light or beam, but the plan’s priority remains the health and safety of the worker in low-light or night conditions.
Recreation at the Housatonic River will be curtailed at certain times during the project, with appropriate signage to be installed in the applicable area to describe the restrictions. GE’s plan incorporates a post-remediation process for representatives to work with local and state officials to enhance the areas along the Housatonic River that were used in the remediation process so those sections can again, if possible, offer canoeing, hiking, and biking.
“GE will evaluate any potential enhancements on a case-by-case basis considering these and potentially other relevant factors,” the plan states. Kittrell said that the EPA’s risk assessment “already concluded that swimming, boating, canoeing, and fishing (excluding eating the fish) are already safe—even without any remediation.”
Although the plan proposes to use licensed haulers to transport the dredged materials in vehicles “lined and covered to avoid spillage during transportation (as necessary),” project opponents have pushed for more specificity as to the tamping down of those covers to prevent the toxic materials from escaping. Those opponents have also voiced fear for the smaller, narrower roads proposed for the project. The plan states that once the EPA signs off on the proposed routes, the existing local roads will be examined to see if they need upgrading to be used for truck traffic, being mindful of the ecological impact from such upgrades.
In addition to a community notification process, GE’s plan outlines a project education program and the introduction of a website as well as an email distribution list for the dissemination of information. To communicate complaints, GE will establish a phone number for use during the project, a dedicated email address to register concerns, and a website link. Emergency response procedures will be included in a plan to be released late January.
Response
Dr. Charles Kenny, who heads up the Tri-Town Board of Health, said the plan has not yet been presented to the group but responded to The Berkshire Edge in his personal capacity and admonished GE for not considering railroad transport in its most recent release. “GE has not truthfully looked at how use of the railroad can dramatically save time by increasing the rate of PCBs removal compared with trucks,” he said in an email.
According to Kenny, by using rail, the remediation project can begin at least a year before trucking transport is ready to go since rail doesn’t have to wait for the UDF to be constructed. Citing officials of the Housatonic Railroad Company (HRRC), he said that the railroad would be available within a year to transport excavated soil and sediment to approved off-site facilities. With trucking to the UDF needing to wait until the facility is constructed in late 2025 or early 2026, rail can be used to remediate the PCBs even before the UDF is built, Kenny said. The prior permit of 2016 provided for all excavated material to be taken out of state.
Although GE’s method is to excavate the remediation areas sequentially and to use trucks for that transport, trucking doesn’t allow for the areas to be remediated simultaneously—shaving time off the slated 10 to 13 years of the project—as that would increase the numbers of truckloads per day “proportionately,” Kenny said.
“GE’s plan has sacrificed concurrent excavations, which would save time, because the required increased truckloads per day would be so obviously intolerable that even EPA would have to object,” he said, adding that rail could handle concurrent excavations.
Kenny advocates that his recommendation for rail transport doesn’t conflict with the 2020 permit as no documents require all or part of the excavated material go into the UDF: “No minimum amount is required to go to the UDF.” By using rail with concurrent excavations, he said the remediation process is sped up and “in the public’s interest” while hauling most of the PCBs away from the Berkshires.
“Every ton of PCB waste that does not go to the UDF makes the UDF less economically beneficial for GE,” Kenny said. “GE prefers to keep as much of the PCBs here in the Berkshires and therefore has disregarded the EPA stated concern that delay in PCB removal poses an increased risk to public health.”
Comments and public input on the Quality of Life Compliance Plan should be sent to R1Housatonic@epa.gov by March 29.
Click here to view maps of the slated areas of remediation for the Housatonic River’s Rest of River range extending from Pittsfield to Connecticut which are a part of General Electric Company’s proposed Quality of Life Compliance Plan released December 20.
Click here to view GE’s Quality of Life Compliance Plan released on December 20. The proposal seeks to mitigate possible negative effects to the communities involved in the Housatonic Rest of River remediation plan.
