Part two of a three part series. To read Part 1, click HERE.
If the solutions were easy, there wouldn’t be problems.
Join us as we look at issues facing Great Barrington and discuss the complexities, the competing interests, the less obvious costs or consequences, and the missing information that explains why It’s Not That Simple.
We both serve on elected boards in Great Barrington but we aren’t here representing those boards or the town. We try not to give opinions, but if we do, they are our own.
This column is a companion to the WSBS (860AM, 94.1FM) radio show, It’s Not That Simple on the air every other Friday at 9:05AM. Listen to the podcast here.
Ed Abrahams is seeking re-election to the Selectboard. Due to the Federal Communication Commission’s Equal Time rule, Ed will be off the air until after the Great Barrington Town Elections on June 30.
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In Part 1 of our series on the Rest of River agreement we talked with Bryan Olson, Region 1 Director of the Superfund and Emergency Management Division of the Environmental Protection Agency about the settlement which was announced on February 11, 2020. In the course of our 25-minute radio show we asked Mr. Olson many questions but we still had many questions we didn’t get to. Mr. Olson agreed to answer additional questions in writing.
In part 2 of our series we begin with the final few questions of the interview, followed by Mr. Olson’s answers to our written questions. Many of these questions were taken from concerns raised at several public forums about the settlement. Our conversation with Great Barrington assistant town manager Chris Rembold will be in the third and final part of this series
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It’s Not That Simple (INTS): We haven’t gotten to how the dump will be built, but there is a liner in the dump to keep the PCBs from getting into the groundwater. We received a comment that the warrantee of the liner is void if it comes into contact with toxic waste. [Page 22 of this powerpoint has a diagram of the proposed landfill.]
Bryan Olson (BO): I don’t know where that comes from. We’ve looked at studies from people that manufacture the liners and from government agencies doing these studies and we’ve seen anywhere from a 400- to 800-year lifespan of these liners. There are going to be two liners, not just one, at the bottom. The second one is the “safety” liner.
But to be clear, these levels of PCBs do not require a liner. We could have put them in place with no liner at all. So, the liner itself is an extra, added protection and then we have a double liner. The PCBs that we put in a landfill like this one could be 5,000-10,000 ppm. That’s the way these chemical landfills work but this landfill is taking really low-level waste. In some ways, it’s “belts and suspenders,” but we felt that if we’re going to put a big landfill here let’s do it right and have no question about the protections. We have no question of the protection of this landfill given the level of contaminants we are putting in there and given how it’s going to be built. In fact, we would encourage some kind of reuse of this area after it’s done.
[The next two questions deal with new technologies that can remove PCBs from soil and/or render them harmless. This is an issue that keeps coming up at public meetings. It has been reported that some of these technologies have worked elsewhere but that EPA refuses to require them in this settlement.]
INTS: EPA Detroit is allowing for experimental remediation. (Corrective measures that eliminate or render PCBs harmless.) There has been talk about alternative remediation. Why is Region 1 not exploring an alternative?
BO: In our corrective measures study, we explored many alternatives, some of which we kept in the corrective measures study and some got taken out early on because they weren’t possible. Some that have been discussed are in our corrective measure study. In this agreement, EPA agreed to specifically solicit research and pay for it. The EPA is going to do it because we feel it is something that can benefit not just New England but the rest of the country.
There is no failsafe technology. In fact, we think the best technology for this level of PCBs is landfilling, because if we use one of these other technologies we might knock it down from 20 ppm to 5 ppm, or even 1 ppm, it still needs to be put somewhere. You still need a landfill. With incineration, we go into many communities that say ‘no way’ to having an incinerator. Some of the people that are arguing for alternatives here have been arguing against the incinerator in Pittsfield, GE’s incinerator. They are not failsafe. They are burning the material and releasing it into the air and hopefully scrubbing out the contaminants. It can be done, but the same concerns about air contamination are magnified when you are talking about incinerators and it could take 50 years to incinerate this stuff.
INTS: And you’d still have to deal with the ash.
BO: Half of it or maybe more of it will be ash and you’d have to dispose of it…There are things in the ash that aren’t great either. There are concerns with all of [the alternatives] and I would encourage people to look at our corrective measure studies. We went through all these studies in that. But again, we’re not giving up on the alternative technology part of it.
Written Questions and Answers
INTS: PCB remediation takes place all over the world, with many approaches such as carbon sequester, separation, thermal desorption, bioremediation, and phytoremediation. It is understood that alternative approaches will be explored as part of the settlement. What and how will these technologies be developed and deployed?
BO: There are no in-place remediations that EPA is aware of where these techniques have been used to treat this type of PCBs at this scale. In the United States, almost all large-scale PCB sites have landfilled the soil and sediments . That’s a big reason why in this Settlement Agreement EPA has committed to a continuing effort towards the identification of opportunities to apply existing and potential future research resources to PCB treatment technologies and will solicit research opportunities for research institutions and/or small businesses to target relevant technologies. In the coming weeks, we will begin to put together a plan for looking at opportunities such as on-site technology demonstration efforts and pilot studies. Consistent with the adaptive management requirements in the Final Permit, EPA will consider the applicability of any promising research for use at the Housatonic Rest of River site.
INTS: Does New England weather make a dump a less viable and safe option?
BO: No, there are hundreds of capped landfills in New England that have been designed to successfully withstand New England’s climate.
INTS: The bottom of the landfill will be 15 feet above the highest anticipated water level and 1,000 feet from the river. Is that safe enough?
BO: Yes, even without a liner, we would not expect significant leakage from these low concentration soils and sediments. The purpose of the 15 feet is to ensure that the soil and sediment is not constantly in contact with the groundwater. Most historic landfills that EPA investigates have a portion of the waste material sitting within the groundwater table. That is a situation that we want to avoid, and the 15 feet provides that assurance. As far as the 1,000 feet [from the river], it is most important that this location is well above the river elevation. If we were closer to the river, either in elevation or distance, river flooding would be another situation that we would have to design for. Given the elevation and distance from the river, erosion as a result of river flooding will not be a realistic concern.
INTS: Can you comment on the allegations made in this article by the Berkshire Environmental Action Team concerning the Allendale site?
BO: It appears that BEAT’s web page has had only one minor update since 2006 and is out of date. Sampling at Allendale School has been ongoing since 2000, but beginning in 2006, there has been a significant increase in sampling. A summary of sampling efforts at Allendale School between 2006 the present includes:
- Soil sampling in the playground area—all 20 sample results were less than 0.1 part per million (ppm), well below EPA and Mass DEP standards;
- PCB air sampling—over 160 air samples since 2007, with all results below EPA risk-based screening concentrations;
- Groundwater monitoring—with results confirming that groundwater flows away from the School and PCB concentrations in the wells located between the school and the landfills are all well below relevant standards;
- Monitoring conducted by Massachusetts Department of Public Health (DPH): In 2006, Mass DPH conducted extensive testing for PCBs both inside and outside of the school. This included air samples, wipe samples (e.g., dust on a surface), carpet dust, vacuum bag dust, and unit ventilator samples. The samples were analyzed by three different labs, including one recommended by HRI. In addition, Mass DPH conducted blood serum sampling for both adults and children. Mass DPH concluded:
“Specifically, based on the Department’s evaluation of indoor environmental testing and blood samples analyzed for serum PCB level, the MDPH/BEH determined that results did not appear to reveal unusual opportunities for PCB exposures to the Allendale School community and that levels reported for indoor air in the school were below health-based screening values. Results of the blood serum testing for all adults and children who participated generally show low PCB levels. The U.S. Centers for Disease Control and Prevention (CDC) reviewed the data as well and concluded that the serum testing results were low and PCB congener patterns were consistent with data seen in the general population.’
- The full report is available here.
Thus, for the purposes of this question, the conclusion is that soil, groundwater, air, blood serum and other sample results indicate that the landfills are not resulting in exposure above risk-based standards.
INTS: Is the Schweitzer Mill dump in Pittsfield leaking?
BO: Just to clarify, the Schweitzer Mill landfill is in Lee, not in Pittsfield. It is one of two landfills that are in the area around Lane Gravel Pit. Massachusetts DEP is overseeing the work at that location, so please contact them for more information about the status of the Schweitzer Mill dump.
INTS: GE successfully pushed the Berkshires into an agreement back in the 1990s (the Consent Decree) by threatening to close the plants and move all the jobs away. Were they able to get a cost sharing agreement where the Feds paid for a sizable portion of the first part of the cleanup?
BO: In the original Consent Decree, GE was required to execute and pay for 27 out of 28 cleanup areas in Pittsfield. The one exception was the 1½ mile section of the Housatonic River downstream of the GE plant site. EPA executed that cleanup and shared the cost with GE using a sliding scale formula that can be found in the Consent Decree. GE is also required to execute and pay for all of the Rest of River cleanup.
INTS: Does the agreement require GE to pay for hookups to town water for those near the site on well water? If the dump is safe, why the necessity for water hook ups?
BO: While likely not necessary to protect the water supply that is upgradient of the landfill and within 500 feet, state regulations require that no well be within 500 feet of a landfill. As a result, EPA required GE to provide a hookup to town water for any well that is within 500 feet of the proposed consolidation location.
INTS: Has anyone done air monitoring of PCB exposure along the Housatonic?
BO: For Rest of River, GE conducted sampling in 1995 at Woods Pond, and the average PCB concentrations in air were 0.0033 micrograms per cubic meter (ug/m3). In 2000, EPA collected air samples at the former DeVos Farm property and at October Mountain Road and did not detect the presence of PCBs in the air. In 2018, EPA collected four samples adjacent at Rising Pond, and the PCB concentrations ranged from 0.0004 to 0.0009 ug/m3. For context, EPA risk-based screening level is 0.0049 ug/m3.
INTS: Are all of the PCBs being removed from the river?
BO: As we have stated before, all PCBs in the river and floodplain that pose an unacceptable risk will be dealt with as part of the remedy. In terms of what sediment is being capped as opposed to removed, the agreement reduces the capping in the river from 300 acres down to 200 acres. Because the amount of removal necessary for cap placement will depend on cap thickness (which will be established in the future design documents), it is impossible to determine the mass of PCBs that will be present under cap once completed. That said, with less reliance on capping and additional excavation, the amount of PCB removal from the river will no doubt be larger – but we have no calculation of such an estimate at this time.
As background, the 25 percent figure that has been quoted in the past was a simple comparison made in 2012 for floodplain and soil that included roughly 1 million cubic yards of soil/sediment to be potentially proposed for removal vs. an estimated volume of over 4 million cubic yards of contaminated soil and sediment exceeding 1 part per million PCBs in the River and top foot of the floodplain. We will only be including PCBs in the denominator that create an unacceptable risk. That is not the case with the totality of the 4 million cubic yards.
The 2016 Permit’s 1 million cubic yard estimate could be compared to the largest sediment/floodplain cleanup option considered in the study, which included roughly 3 million cubic yards of soil/sediment removal (1 million vs. 3 million = 33 percent). This anecdote has nothing to do with PCB mass being removed or otherwise being addressed by capping. The 2014 Statement of Basis included estimated mass of PCBs being removed by various alternatives considered. EPA’s selected alternative in the 2016 Permit includes an estimate of roughly 47,000 pounds of PCBs to be removed as compared to the most aggressive alternative that was considered removing 94,000 pounds of PCBs. (47/94 = 50 percent).
INTS: Many EPA scientists say every dump will eventually leak. What guarantees are there that the Lee dump will not leak?
BO: Most of the landfills that have been capped across the country are historic landfills that never had a liner. It is important to provide more context in order to respond to this question thoroughly. I’d be surprised if that kind of pessimistic sentiment would carry over to a landfill for lower-level PCBs that is to be designed as if it were containing very high-level contaminants. Additionally, this landfill is backed up by a federal court order to reinforce all the requirements on GE in perpetuity, as well as a $150 Million surety bond to provide financial assurance if GE cannot.
We need to keep in mind, though, that the same contaminated soil and sediment is currently sitting in the bottom of the river, the backwaters and ponds, the riverbanks and in the floodplain with 25 percent of it sitting right in Woods Pond. This situation has been ongoing for 75 years with no controls of any kind. People live next to it, walk in it, swim in it, canoe in it, etc. EPA believes it is most important that we get this cleanup proceeding to address the contaminated soil and sediments sooner rather than later. Once we get the contaminated material out, we will segregate the worst soils and sediments, send those off-site and then consolidate the low-level material in a safe, secure and well-designed landfill that is designed as if we were disposing of the more highly contaminated material.
As far as leaking, a properly designed consolidation unit with a double-liner, leachate collection and engineered cap will not realistically leak. With that said, “leaking” in this instance would likely mean that the water that was still in the moist soils and sediment would somehow get through both liners and end up dripping into the underlying soil. This water would be, at worst, mildly contaminated, because the PCBs have an affinity for the carbon in the soil. If the PCBs didn’t stick to the soil particles and instead get into the water, they would have long ago “leaked” into the water in the river and made their way out of Massachusetts south to Connecticut and then moved into Long Island Sound.
INTS: EPA says PCB concentrations of 25ppm are not toxic. Environmentalists say there are no safe levels. Can you comment on the safety of PCB concentrations of 25ppm? Between 25ppm and 50ppm? Above 50ppm?
BO: Risk is defined by exposure multiplied by concentration. If there is no exposure, then there can be no risk. If there is exposure, the higher the exposure and the higher the concentration, the risk becomes greater. It’s important to keep in mind that EPA sets cleanup standards based on very conservative assumptions. For example, the Toxic Substances Control Act (TSCA) regulations allow for 25 ppm to be left in place in a low occupancy area without the need for an engineered cap or soil cover. For low occupancy areas, EPA assumes that a person would be directly contacting these soils and sediments for 335 hours per year (a little less than an hour per day). Landfills such as the proposed consolidation unit, are designed to hold PCBs at concentrations much higher than 50 ppm, even into the thousands of ppm. As stated in other forums, we expect the average concentration going into the consolidation unit to be less than 25 ppm which would normally not require an engineered cap if the location met the criteria for a low occupancy area described above.
In part 3 of this three-part series, we will welcome Chris Rembold, Great Barrington Assistant Town Manager and Director of Community Development to explain the negotiation process, and the benefits of the negotiated settlement to Great Barrington and other South Berkshire towns.
Is there an issue you’d like to discuss on the show? Do you have comments about this or previous shows? We invite your suggestions of topics that may be of interest and that might seem simple to address. Maybe there IS an obvious solution we haven’t thought of, or maybe It’s Not That Simple.
Listen to our show on WSBS (860AM, 94.1FM) every other Friday at 9:05 AM.