Housatonic Rest of River — In conjunction with the Housatonic River remediation project to clean up the Rest of River region (ROR)—from the confluence of the waterway’s east and west branches through Connecticut—General Electric Company (GE) submitted its Revised On-Site and Off-Site Transportation and Disposal Plan to the Environmental Protection Agency (EPA) on October 15, pushing for more hydraulic pumping as a mode of transporting the project’s toxic materials and suggesting a hybrid truck/rail method to move materials not able to be pumped. The proposal also offered three sites for rail sidings, or areas to load and offload materials, to allow railroad transport for some of the materials not transported through the hydraulic method.
GE’s Revised On-Site and Off-Site Transportation and Disposal Plan can be found here.
History, reasons for revision
GE’s original October 31 submission alarmed local and statewide stakeholders and residents who decried the document’s slant toward transporting dredged soil and sediment laden with the now-banned polychlorinated biphenyls (PCBs) from the Housatonic River predominantly via trucking with hydraulic pumping used to a limited extent. Those responding to the submission deemed trucking to be a more dangerous transportation option for human health and the environment, citing the GE plan as only giving a slight nod toward using rail as a choice. In June, the EPA referred the document back to GE, strongly advocating company engineers evaluate other transportation options, including rail, as well as more efforts to gain efficiency in the process.
The process stems from decades of GE depositing PCBs into the waterway from its Pittsfield plant. A December 2020 permit encompassing the ROR remediation was agreed to by the EPA, environmental departments, and town officials—including a representative each from Great Barrington, Lee, Lenox, Sheffield, and Stockbridge—allows for the most contaminated materials to be transported out of the area, with those materials containing the lowest contamination destined for an Upland Disposal Facility (UDF) in Lee.
The 2020 permit also placed the authority to approve GE submittals for the Housatonic River cleanup squarely with the EPA, with Massachusetts and Connecticut state agencies given an opportunity for review and comment.
Public input on this revised plan is due to R1Housatonic@epa.gov by January 15, 2025.
No such thing as “all-rail” transport; evaluating truck, rail/truck, and hydraulic pumping
The new report acknowledges that “there is no such thing as ‘all rail’ transport for the ROR Remedial Action.” “Where rail transport is used, trucks will be necessary to take removed material from removal or staging areas to a rail loading area [other than when hydraulic pumping is used] and, in most cases (and all cases involving the UDF), from the railroad to the final disposal site,” the document’s Executive Summary states.
The ROR remediation region is divided into reaches or stretches of remediation. Those reaches are: Reach 5, from Garner State Park downstream to Woods Pond (the first significant impoundment), including Reach 5A, spanning to the Pittsfield Wastewater Treatment Plant (Pittsfield), Reach 5B, from the Pittsfield Wastewater Treatment Plant to Roaring Brook (Lenox), and Reach 5C, from Roaring Brook to the start of Woods Pond (Lenox, Lee); Reach 6, Woods Pond (Lenox, Lee); Reach 7, Woods Pond Dam to Rising Pond Dam, including Reach 7A and 7B at Columbia Mill Dam (Lee), Reach 7C, former Eagle Mill Dam area downstream of Reach 7B (Lee), Reach 7E, Willow Mill Dam (Lee), and Reach 7G, Glendale Dam (Stockbridge); and Reach 8, Rising Pond (Great Barrington).
A map of the ROR Reaches 5 to 8 can be found here.
Preliminarily, GE estimates most of the materials to be removed will emanate from Reach 6, at about 537,200 cubic yards, with most of that set for the UDF, followed by Reach 5C at about 261,000 cubic yards and Reach 5A at about 138,700 cubic yards.
The revised transportation plan: how it works
GE’s evaluation focuses on three project transportation methods: truck, truck and rail, and hydraulic pumping, with the latter involving removing the impacted sediment as a slurry, or watery mix, before transporting the materials hydraulically to a dewatering area with pipes and pumps, and then to a disposal site.
The revised document touts a greater use of hydraulic pumping than in the original transportation plan, with that method obviating the need for trucks to trek through local roads with toxic soils and sediment. The plan is expected to take about 13 years to complete, with a total of about 1.065 million cubic yards of material to be removed from the Housatonic River area, including an estimated 100,000 cubic yards transported off site for disposal.
The proposal centers on hydraulic pumping, with that transportation method aimed to account for 79 percent of all material to be removed from the ROR.
For materials not hydraulically dredged from the site, or 21 percent of the removed substances, GE compared four scenarios for transportation: truck transport to both the UDF and off-site disposal facility; truck transport to the UDF and rail/truck transport to the off-site facility; truck transport to the UDF and mostly rail/truck transport to the off-site facility; and mostly rail/truck transport to the UDF and rail/truck transport to the off-site facility. GE selected the final option, advocating trucking as a method that “provides flexibility” for the project since trucks are readily available, allow for easy accessibility to work areas, aren’t dependent on a set schedule as railroad cars are, and have already been used by the EPA in other stretches of the Housatonic River remediation.
According to GE, by using hydraulic pumping along with truck and rail transporting the non-pumped materials, about 24,600 round-trip truck trips will be needed, a savings of 77,800 round-trip truck trips over trucking all materials. Although this scenario “requires the most daily average truck trips during the first years of construction, those trips would be shorter than under other scenarios,” the revision provides.
The proposal includes the construction of rail loading areas at Utility Drive in Pittsfield for materials removed from Reach 5A and Rising Pond in Great Barrington for materials removed from Reaches 7G and 8. A rail loading and off-loading area would be added at Woods Pond Spur in Lenox for material from Reaches 5B, 5C, and 6. This design enables some materials to be loaded directly onto the railcars waiting at the new loading areas, without truck transport.
“It is anticipated that each rail spur/siding and associated support area would take a total of about three months to construct,” the revision states, adding that this construction wouldn’t impact the overall construction schedule.
The rail loading area construction is needed, per GE, because “currently no usable active railroad spurs or sidings [are] available in or near the City of Pittsfield or the Towns of Lee, Lenox, Great Barrington and Stockbridge.”
Owned by the Commonwealth, Utility Drive is near a residential neighborhood. Woods Pond Spur would require the consent of the Berkshire Scenic Railway Museum that is operating on the property since it would be forced to shut down. Rising Pond property is currently owned by GE, but the company is required to transfer it to the town of Great Barrington, retaining enough easements to make it a viable rail siding option.
GE explicitly states that rail isn’t an option in Reaches 5B, 5C, 6, and 7E because the distance to travel by truck to the UDF from those sites is shorter than the distance to take the materials to and from a rail loading area. The report suggested that rail is used as an option for longer transport routes.
“This recommendation gives substantial weight to the preference of some in the community for a reduction in local round-trip truck miles … [with] by far the fewest round-trip truck miles of any of the scenarios evaluated (142,800 miles), with the next highest scenario (245,000 miles) involving over 70% more round-trip truck miles,” the revision states.
In its revised plan, GE proposes the “most likely anticipated routes” to transport materials from the work sites to the UDF or out of the area from its selected scenario that assumes most of the dredged materials will be hydraulically pumped. It states the routes were derived from input by town officials and the community, as well as the EPA, in its June 4 letter requesting revision.
Those routes include:
- Prioritizing Roaring Brook and Woodland roads;
- Avoiding MA-183 through the center of Lenox to the UDF, using US-7 to Walker Street/Willow Hill Road instead, with MA-183 to be used in an emergency;
- For remediation areas north of I-90, US-7 will be used south to MA-102 east to I-90 west, with US-20 through Lee used only as “a secondary or alternate route”; and
- Avoiding MA-102 west through Stockbridge (Reaches 7E, 7G, 8) to I-90 west using MA-102 east to I-90 west, with MA-102 through Stockbridge used only in an emergency.
Truck transport from the eastern side of the Housatonic River is needed should Woods Pond Spur be used for a rail siding site. Those routes include a northern route along Woodland Road, Valley Street, Crystal Street, and Willow Creek Road, as well as the use of Schweitzer Bridge, and a southern route through Lenox Dale along Woodland Road, Willow Hill Road, the Mill Street Bridge, and Crystal Street/Willow Creek Road.
For local roads affected by the project routes, GE stated in its revision that it will evaluate what type of conditioning or upgrade would be required for this use.
Greenhouse-gas emissions, work injuries, and a caveat
The EPA’s July letter urged GE to review greenhouse-gas emissions, or gases such as methane and carbon dioxide that trap heat in the atmosphere. In its revision, GE found that the proposed hydraulic transport measures “should result in lower [greenhouse-gas emissions] than truck or rail/truck transport over the same distance” because less equipment and infrastructure is needed for the pumping method. The company stated it will also incorporate methods to minimize the emissions in its transportation and disposal process “to the extent practicable” with the use of fuel-efficient vehicles, idling restrictions, route planning, as well as employing local staff and local suppliers.
Additionally, in its required evaluation of work and transportation injuries from the project, GE found that the traffic injuries were “relatively similar” in all four transportation scenarios. That process didn’t include hydraulic pumping since no traffic injuries are possible. However, the chosen scenario showed the most work-site fatalities and injuries “due mainly to the greater amount of rail/truck transport and thus the greater amount of loading [and] off-loading of material to [and] from rail,” GE stated.
“The average injury and fatality accident rates for rail are more than a factor of 10 times greater than the average injury and fatality accident rates for large trucks,” the report concludes.
However, GE cautioned that should its project target for production—the removal of sediment and soil—not be met, it would supplement the process with truck transport.
