Rising Pond. Photo: Mickey Friedman

Troubled history of the Housatonic River PCB settlement

The questions I pose are prompted from years working to create strong coalitions to fight General Electric - a rare coalition of former GE workers, sportsmen and women, local Lakewood homeowners whose front- and backyards were contaminated with high levels of PCBs, and environmentalists.

A small roomful of people — the Housatonic Rest of River Municipal Committee — brought together by the Berkshire Regional Planning Commission and “governed by an Inter-Governmental Agreement (IGA) signed by each municipality” have been negotiating the fate of the Housatonic River on our behalf.

They’ve done so in secret without public meetings or any meaningful consultation with the rest of us. Their actions have been ratified by their select boards. While they have the legal authority to do so, I wonder if, had they been a bit more humble, they might have opted for a more democratic process. They have, after all, presumed to decide the fate of a river, its wildlife and the health of the people who live near the river for generations to come — especially those in Lee, who’ll have to live with a massive PCB dump.

The questions I pose are prompted from years working to create strong coalitions to fight General Electric — a rare coalition of former GE workers, sportsmen and women, local Lakewood homeowners whose front- and backyards were contaminated with high levels of PCBs, and environmentalists. In my experience it was always the loud voices and legitimate demands of the people, attending City Council sessions, marching to City Hall, holding neighborhood meetings at the Italian American club, in local churches that worked best. With vigorous community organizing, we forced the Massachusetts Department of Environmental Protection and the United States Environmental Protection Agency to acknowledge that GE — despite its many denials — had indeed allowed massive amounts of contaminated material to leave its plant, then to vigilantly demand action.

While it seems the Rest of River Municipal Committee has placed significant trust in the EPA, our experience differed — with several exceptions, Doug Luckerman and Susan Svirsky. EPA and DEP too often deferred to GE. Here’s a 1982 EPA document, mistakenly accepting GE’s completely inaccurate estimate about the river, then discussing what a productive relationship they had developed with GE.

This 1982 document from EPA’s Region 1’s Water Quality Management Program clearly reveals how woefully inadequate EPA’s assessment of the PCB problem was. The excerpt below reveals how successfully GE had manipulated the environmental regulators. Stewart Laboratories was the author of the 1982 study claiming there were 39,000 pounds of PCBs in the Housatonic. Steven Joyce of the Massachusetts Department of Environmental Quality Engineering, DEP’s predecessor agency, consistently underestimated the massive amounts of contaminated materials that had left the plant.

It was necessary to counter the claim of 39-40,000 pounds of PCBs in the river. Berkshire Regional Planning Commission, by the way, published a pamphlet repeating this misinformation.

Brave GE managers like Ed Bates and Charles Fessenden exploded this myth. Calculating the daily loss rate at Power Transformer, they estimated that a million and a half pounds of PCBs had gone down the drains and into the river, figuring about 500,000 pounds were probably still left.

After I interviewed Ed and Charlie, I interviewed former Pittsfield Mayor Remo Del Gallo: “I can go back 50, 60 years if need be that when the General Electric Company had the oil tanks … those tanks leaked for years and years and years … and the oil flowed down the embankment, under the railroad tracks and then into East Street and what was said uh created a plume and when they say a plume, they’re talking about an underground lake of oil …

“But my real concern at the time was, when I say credibility gap … a fellow by the name of George Rousseau, was in charge of all liquid waste disposal for the General Electric Company since 1936 and he is the one that informed as to where the liquid waste was being dumped – four given sites on General Electric property …

“It came in 30 gallon barrels and 55 gallon barrels, some two-thirds Pyranol, one-third oil; two-thirds water, one-third Pyranol.  And when I say disposed, we’re talking about thousands and thousands and thousands of gallons of oil … including that oil tank that they had up on what is known as Peck’s Bridge, 550,000 gallons of oil, that’s how much – it held that capacity – and it leaked for years and years and years, before 1964 and after 1964.

Now I’ll go back to 1980 when we contacted Angelo Inatosca and he had an associate, Walter Schwartz, they worked for what we called the DEQE, the Department of Environmental Quality Engineering, and they stated that it never penetrated, the plume, the oil never penetrated the southerly side of East Street.  So I took it upon myself to take them up to a place known as Bardo’s Bakery and now we have Hiser, H&S Automotive up there and uh Bardo’s Bakery, I remember he had a sump pump at the bottom of the stairs and I said to Angelo Inatosca at the time and representatives of the General Electric Company and EPA, if there’s no oil in that sump pump I’ll agree with you it never penetrated the southerly side of East Street.  And now when we went up there and uh we checked that sump pump, it was loaded with oil, loaded with oil.”

HRI’s work encouraged others with first-hand knowledge to come forward. Not only did massive amounts of PCB oil leak from the factories into the river, but GE employed an absorbent material — Fuller’s earth — to soak up the large amount of oil that spilled from the transformers under test to the factory floors.

GE engineer Kelly Niederjohn’s memo details PCB leaks and dumping

Ed and Charlie spoke of Kelly Niederjohn, who was increasingly troubled by what he knew about GE’s extensive dumping regime:
CF: Sure, we’ll look at Kelly
EB: Yeah, Niederjohn …
CF: He was terrible, you know.
EB: And now he’s concerned about the Fullers Earth … which, you know, there’s a million and a half pounds of Fullers Earth buried somewhere around Pittsfield.
CF: You bet, well they’re digging that up little by little.
EB: Little by little …
CF: They’re finding the sites.
EB: Well if I were them I’d be worried about where the Stop N’ Shop is because there used to be a big dump right in back of the Stop N’ Shop. Remember there used to be an outdoor movie there.”
CF: That’s a wetlands area too …”

There was more oil-soaked Fuller’s earth than GE knew what to do with. Tractor trailer loads were taken to the Pittsfield city dump. GE utilized other off-site dumping grounds. GE gave away PCB oil-soaked flooring that employees used to build outdoor decks on their homes.

Truckers started to come to tell us exactly where they had dumped, concerned about liability. But DEP still didn’t believe us when we told them about Dorothy Amos Park, the hundreds of homes, Goodrich Park, the small businesses of Newell Street. So, we pressured DEP to set up an anonymous 800 number tip line. And the phones started to ring.

Demonstration by contaminated homeowners, Lakewood neighborhood. Photo: Mickey Friedman

We pressured DEP to sample 470 properties and clean 185 of them. One home had levels of 44,000 parts per million. DEP’s acceptable level for residential properties is 2 ppm.

All accomplished by sustained community organizing. By building trust. In the light of day. Without the need for confidentiality agreements or behind-closed-doors secrecy.

Of course, we made mistakes. A bunch of Davids fighting several Goliaths. Most without technical backgrounds, and yet we read countless reports on sampling techniques, PCB levels in fish and ducks, in soils and sediments, a wide variety of health studies. We wrote comments in response to decades’ worth of reports from GE, DEP and EPA. We testified at public hearings. We even wrote legal briefs. We became citizen experts.

I appreciate the pressure the Rest of River Municipal Committee were under. Yet, based on what they said during the Lee and Great Barrington public meetings, let me respectfully suggest they didn’t fully appreciate the critical health risks of low levels of PCBs, the reality of remedial technologies, and the severe limitations with landfilling.

I’m guessing EPA and/or Berkshire County Regional Planning Commission’s consultant argued that unless they accepted this agreement, GE might walk away, withdraw what it had offered and go to court, costing the towns a fortune.

No one knows what GE is going to do. EPA’s Environmental Appeals Board noted that in its appeal of EPA’s clean-up order, GE contested “both the scope of the cleanup and the requirement to dispose of the excavated materials at an off-site landfill.” Then EAB ruled: “The Region did not clearly err in choosing a cleanup remedy for the Housatonic River that is more extensive than GE’s preferred alternative. GE has not demonstrated that the Region clearly erred in rejecting GE’s claim that a less-extensive remedial alternative would reduce PCB levels in fish tissue to an equivalent degree as the remedy selected by the Region … GE has not demonstrated that the Region clearly erred in choosing a cleanup plan for the Housatonic River floodplain based on the Region’s estimate of human exposure to PCBs in the floodplain … GE has not supported its claim that the selected remedy will have a long-term negative impact on the Housatonic River ecosystem.” It is just as reasonable to assume the courts would second this judgment rather than allow GE to walk away from its responsibility to clean the river.

While the EPA judges never quarreled with the need for a comprehensive cleanup, they noted “The Region failed to exercise considered judgment in deciding that the contaminated materials excavated during the cleanup should be disposed off-site … This lack of considered judgment necessitates a remand of the Permit decision to the Region to reconsider selection of the disposal location.” EPA then failed to offer a more convincing argument.

Why? Because EPA knew that it had already created a precedent in the 1999 Consent Decree allowing GE to dump the contaminated material from the first 2-mile clean-up into two Pittsfield dumps, the unlined Hill 78 and newly constructed dump at Building 71. Then EPA insisted its decision was fully protective of human health.

I imagine the Rest of River Municipal Committee considered EPA an ally when it came to preventing a local dump.

Let me say something about public pressure. When HRI challenged the Consent Decree and took our concerns to Federal District Court, we were attacked by John DeVillars, Region 1 director of the EPA. And the Berkshire Eagle, the mayor of Pittsfield and City Council, most of the business leaders of Berkshire County, the Commonwealth of Massachusetts and state of Connecticut all accused us of ruining their chances to clean the river.

Then, the Department of Justice flew its attorneys up to Boston to threaten us. Ultimately, we withdrew our legal action and negotiated a settlement with the EPA. Sound familiar? We gained more community participation, more monitoring, more testing, earned relief for contaminated property owners etc., etc. And celebrated this pledge from EPA Region 1 Administrator Mindy Lubber:

EPA will actively investigate the potential for using innovative treatment technologies for the remediation of the Rest of the River … the EPA will conduct a search of appropriate national databases to determine potentially applicable treatment technologiesEPA will, with public involvement, evaluate whether or not to conduct pilot treatability studies for innovative treatment technologies for the potential cleanup of the Rest of the River section of the Housatonic River. For example, EPA will consider soliciting bids from potential vendors for treatability studies.” (Emphasis added.)

We took this pledge to heart. Twenty years later, there was never a series of real, publically viewable treatability studies with Housatonic River sediments and bank soils. Had the Rest of River Municipal Committee consulted with us, would they have been so satisfied by their EPA promise?

“The EPA will facilitate opportunities for research and testing of innovative treatment and other technologies and approaches for reducing PCB toxicity and/or concentrations in excavated soil and/or sediment before, during, or after disposal in a landfill. These opportunities may include: (1) reviewing recent and new research; (2) identifying opportunities to apply existing and potential future research resources to PCB treatment technologies, through EPA and/or other Federal research programs … GE and EPA will continue to explore current and future technology developments and, where appropriate, will collaborate on on-site technology demonstration efforts and pilot studies, and, consistent with the adaptive management requirements in the Final Permit together, will consider the applicability of promising research at the Housatonic Rest of River site.” (Emphasis added.)

Is this promise worth the paper it’s printed on?

Re the other provisions their negotiations secured. One hundred acres’ worth of reduced capping, and more removal, GE’s Quality of Life Compliance Plan to address issues of noise, odor, and traffic, the use of activated carbon in vernal pools. Payoffs of $8 million to Pittsfield, $25 million to Lenox and $25 million to Lee, and $1.5 million and the donation of 149 acres GE had purchased for a proposed dump near Rising Pond to Great Barrington. More cleanup of contaminated sediments behind several dams and a cleanup of Mass Audubon’s Pleasant Valley Wildlife Sanctuary. And a cleanup to a level of no more than 1 part per million (ppm) in Reach 5C above Woods Pond.

While the municipal committee credits its secret and confidential negotiations, these are demands that HRI has publically advocated for years — and could have been won had the committee and select boards joined their constituents in a public campaign for a more comprehensive cleanup.

I suspect GE agreed because it gained more than it gave up. Because EPA and the committee didn’t insist on an even more comprehensive cleanup, GE saved a fortune — saved another fortune when they agreed to a five-football-fields-long, 20-foot-high massive PCB dump in Lee, Massachusetts.

I’ve learned along the way that if GE gives you $10 million, it’s because you’re allowing it to save at least 10 times that much. A single example: The City of Pittsfield didn’t challenge GE’s right to dump the contaminated sediments and bank soils from the 2-mile cleanup in Hill 78 and the Building 71 dump in return for $10 million. The City of Pittsfield regarded that as a victory.

What the people of Pittsfield never knew is that the City had for years allowed GE to use the city landfill for free, that the City never sued GE for poisoning the city’s groundwater. Pittsfield will never be able to drink the water from the aquifer beneath the former Epstein Farm. Why, the barrels of GE’s PCB-contaminated waste it had dumped in the old city landfill leaked and created yet another underground PCB lake, which contaminated the aquifer.

How much is clean drinking water for a city worth for 100 years? $10 million times how much?

The committee tells us the “Settlement Agreement gives the municipalities, as well as affected property owners and neighborhoods, greater opportunities to review and provide input into these EPA decisions.” But by negotiating in our name without consulting us about the most important decisions, they’ve effectively stole that opportunity from us. Without holding community conversations, it has agreed to a massive PCB dump in perpetuity for the people of Lee. It surrendered truly effective and democratic public input.

At the two public meetings, the representatives seemed annoyed their efforts weren’t appreciated. The committee’s press release assures us that “At the start of mediation, the Committee made it clear to EPA that if it was not satisfied that a landfill containing PCBs would be protective of public health, safety and the environment, it would not continue negotiating towards a settlement … Using the Towns’ legal funds, ESS, an environmental consultant, was hired to ensure those goals were reached. The landfill, as designed and specified in the Settlement Agreement, meets those standards.” (Emphasis added.)

But recent research reveals the inherent limitations of the technology itself, and potential serious health effects. The “Laboratory Study of Interface Characteristics of Landfill Liners” by Faisal Hj Ali et al, notes: “Some recent landfill failures have indicated failures taking place along low friction angle zone between subsoil and geosynthetic or geosynthetic layers, clay liners, landfill cover slopes in static stage or under seismic condition.”

“The failures through liner system beneath the waste mass are common, due to multiple layer components consisting of clay, soil and geosynthetic materials. Double-lined systems can consist of as many as 6 to 10 individual components. As such the interfaces resistance of the individual components against shear stress could be low and cause potential failure plane.”
(http://nexusec.com/conference_paper/Laboratory Study of Interface Characterictics of Landfill Liners.pdf)

Martine Vrijheid’s “Health Effects of Residence Near Hazardous Waste Landfill Sites: A Review of Epidemiologic Literature” notes: “Increases in risk of adverse health effects (low birth weight, birth defects, certain types of cancers) have been reported near individual landfill sites and in some multisite studies, and although biases and confounding factors cannot be excluded as explanations for these findings, they may indicate real risks associated with residence near certain landfill sites.” (Page 101)

“Geschwind et al. investigated the risk of congenital malformations in the vicinity of 590 hazardous waste sites in New York State. A 12 percent increase in congenital malformations was found for people living within 1 mile of a site. For malformations of the nervous system, musculoskeletal system, and integument (skin, hair, and nails), higher risks were found. Some associations between specific malformation types and types of waste were evaluated and found to be significant.” (Page 109)

“A number of studies have suggested a relationship between residential proximity to landfill sites and adverse pregnancy outcomes. An increase in infants with low birth weights has been the most consistent finding in single-site studies (Page 111, emphasis added).

In 2000, the World Health Organization declared that: “The universal distribution of PCBs throughout the world, suggests that PCBs are transported in air … The ability of PCBs to co-distil, volatilize from landfills into the atmosphere (adsorption to aerosols with a particle size of < 0.05–20 µm), and resist degradation at low incinerating temperatures, makes atmospheric transport the primary mode of global distribution. In a study in the USA, 92 percent of the PCBs detected were in the vapour phase.” (Emphasis added) (http://www.euro.who.int/__data/assets/pdf_file/0016/123064/AQG2ndEd_5_10PCBs.PDF)

Similarly, Nancy Bettinger of DEP’s Office of Research and Standards noted: “Endocrine disrupting chemicals found at waste sites can have effects at environmentally relevant concentrations. Endocrine effects have been reported at concentrations that are: lower than risk-based concentrations conventionally derived for site management, and/or consistent with ambient air exposures not normally assessed at waste sites.” Bettinger cited several examples where “Low-level site-related exposures could affect human endocrine systems.” (Emphasis added) (http://www.astswmo.org/Files/Meetings/2008/2008Annual_Meeting/Presentations/CERCLA Brownfields/Bettinger-Endocrine-FINAL.pdf)

Even landfill liner manufacturers acknowledge their limited guarantee: Up To 20 Years Warranty: (https://www.westernliner.com/liner-materials.html)

HRI has often hosted Dr. David Carpenter, professor of environmental health sciences at the School of Public Health at the University at Albany. Dr. Carpenter has done groundbreaking work based on the volatilization of PCBs utilizing the New York state hospital datasets, correlating patient visits with ZIP codes to reveal residences close to toxic waste sites and/or the Hudson River. He found that those more likely to be exposed to these chemicals had increased incidences of a variety of diseases like diabetes, heart disease, stroke, hypertension, thyroid disease, endocrine disease, asthma and infections.

Dr. Carpenter found significant cognitive impacts in Mohawk adolescents exposed to PCBs, including delayed recall, long term retrieval, comprehension and auditory processing.

At the two meetings I watched, committee members seemed to minimize the health risks to those who live in proximity to the river and to the planned dump. But there is no safe level of PCBs. And there are reasons to question their claim that the Lee landfill will “be protective of public health, safety and the environment.” Every PCB left unremediated in the river, every PCB that is landfilled and not treated, is a real risk to the environment and human health. It’s why HRI continually advocated for a fishable, swimmable river.

EPA attempted to reassure audiences by referring to a Massachusetts Department of Public Health study that revealed low levels of PCBs in the blood of locals. But here’s the history of local PCB blood studies.

Let’s go back to former Pittsfield Mayor Remo Del Gallo who helped to host the first blood testing of Lakewood residents and GE workers. Dr. Rosenman and Dr. Richard Clapp found 43 people with a history of having worked at GE had a median PCB level of 21.7 ppb (parts per billion); 12 people who hadn’t worked at GE but did live with someone who did had median levels of 15.6 ppb; 7 residents of the contaminated Lakewood neighborhood but hadn’t worked at GE had median levels of 8.3 ppb; and 9 people who hadn’t lived in a contaminated neighborhood or worked for GE had median levels of 6.9 ppb.

More than 15 years later, in response to pressure from HRI, MDPH did its Housatonic River Area PCB Exposure Assessment Study, Testing two groups: “Participants from the Exposure Prevalence Study who received blood tests had a mean serum PCB level of 5.44 ppb and a median level of 3.93 ppb, with one person (1.4 %) over 20 ppb. Participants in the Volunteer Study had a mean serum PCB level of 9.07 ppb and a median level of 6.60 ppb. with five persons (6.3 %) over 20 ppb.”

MDPH concluded: “in the United States, typical PCB levels, in the serum of non-occupationally exposed individuals range from about four to eight ppb, with 95 percent at or below 20 ppb (ATSDR 1996). The serum PCB levels found in the Exposure Prevalence Study and Volunteer Study were generally consistent with reports, of non-occupationally exposed individuals. Since the levels obtained from the Exposure Prevalence Study were from the participants with the highest risk of potential environmental exposures (the ones selected due to residence within half a mile of the river and due to highest scores), it is reasonable to believe that serum PCB levels of most non-occupationally-exposed residents in the HRA communities should be in the national background range.” (Emphasis added.)

Tragically, MDPH used an incorrect figure for the background level — the level ordinary people without any occupational exposure or unusual exposure to PCBs have in their blood. MDPH reassured the people of Berkshire County that their PCB blood levels were average and not unusual, when in fact the proper background level was not 4 to 8 ppb but instead 0.9 to 1.5 ppb. Someone with 6 ppb had levels four times and almost seven times higher than average. In fact, everyone who was tested, over the course of these many years, had significantly higher levels of PCBs in their blood than the average American.

Not surprisingly, GE used this incorrect conclusion, taking out full-page ads in the Berkshire Eagle:

GE full-page ad, Berkshire Eagle

So, let me suggest to the committee and select boards that when your constituents anecdotally report increases in incidences of cancer and other diseases and express their concern about possible exposure to volatilized PCBs from the Housatonic, at the least, they deserve your attention and support. At best, there should be a united call from all the towns for a new, more rigorous, more accurate public health study.

Now let me make this personal. I’ve lived in Great Barrington for many decades now. I can’t see Rising Pond without dreaming — from the very beginning when I first saw Rising, from the days I’d be out there with my camera, making Good Things To Life, as dusk approached, trying to capture the beauty of Rising.

For me, Rising Pond was special because of what it might mean for my town. I couldn’t help but see the family picnics, the kids swimming. You may think it’s crazy to imagine kids swimming in Rising. And I can’t fault you for that. But for me, it’s been a reason to spend many decades of my life fighting for a fishable, swimmable Housatonic River.

HRI sued the EPA and GE over the 1999 Consent Decree. Imagine how much stronger our case would have been if we were joined by the City of Pittsfield? I’m not sure the Rest of River Committee and the select boards realize that they have made it that much harder for the rest of us to make our dreams come true. Because if HRI and other disappointed Berkshire residents sue EPA and GE over this new agreement, they’ll now be suing the City of Pittsfield and the towns of South County. How much stronger would the case be if they were joined by the towns of South County?

HRI made the dream of remediated Lakewood homes come true. Few believed as HRI did that the first 2 miles of the Housatonic would be cleaned. I still believe it’s worth fighting for a Rising Pond clean enough for the fish and the birds and clean enough for our children to swim.

It’s not science keeping us from our dreams. It’s not engineering. It’s money — money GE doesn’t want to spend, money EPA won’t force GE to spend.

Several town representatives claimed there is no viable way to treat the PCB-contaminated sediments and soils right now. But HRI has been talking about thermal desorption for years now. And with each passing year, the case for thermal desorption becomes ever more compelling.

Here’s the evidence: United States Agency for International Development’s collaboration with the government of Vietnam on a 10-year (2009-2018), $103.5 million project to successfully clean the dioxin-contaminated Danang Airport.

Danang is so very appropriate because USAID was initially committed to landfilling until, in 2010, it engaged in an environmental assessment process evaluatinga number of possible dioxin remediation technologies. Thermal desorption treatment was determined to be the most effective and scientifically proven method for destroying dioxin and to have the lowest potential impact on human health and the environment given the specific conditions of the site.

“The technology is an innovative dioxin destruction technology that uses conductive heating and vacuum extraction to remediate soil and sediment contaminated with dioxins. The excavated soil and sediment is placed into a completely enclosed above-ground pile structure.

The contaminated soil being trucked in. Image courtesy USAID
Cross section of facility showing liners and protective layers, heating pipes and vapor vacuum system. Image courtesy USAID

“Heating rods operating at temperatures of approximately 750 to 800 degrees Celsius (°C) (1400 to 1500 degrees Fahrenheit [°F]) raise the temperature of the entire pile to at least 335°C (635°F).  At that temperature, the molecular bonds holding the dioxin compound together break, causing the dioxin compound to decompose into other, harmless substances, primarily CO2, H2O and Cl2. (Emphasis added.)

Vapor extraction. Image courtesy USAID

“After testing confirms that the soil is clean, the phase 1 clean soil and sediment will be removed and the phase 2 contaminated soil and sediment will be placed in the pile structure to undergo the same heating process.”

AID reports: “The project was a resounding success in treating dioxin contaminated soil and sediments, with resulting post-treatment dioxin levels well below the required limits.”

In response to the question of whether thermal desorption was cost effective in comparison to other remedial solutions, USAID wrote:

“The Project cost 669 USD per ton to treat the material compared to similar methods which ranged from 337 – 5,205 USD per ton. The Danang project treated roughly 7.8 times more material than did the lowest cost project. Conclusions: The project was cost effective, being the third least expensive project examined out of 10 technologies.”

The U.S. Embassy noted: “The project has successfully treated over 90,000 cubic meters of contaminated soil and sediment through thermal desorption and safely contained an additional 50,000 cubic meters of low concentration, dioxin-contaminated material. USAID and MND tested the treated soil and sediment to determine if the cleanup objective of 150 parts per trillion (ppt) was achieved. Phase 1 treated soil was less than 9 ppt and Phase 2 even lower (<1 ppt), exceeding all project goals.”

After years of dealing with Region 1, its apparent preference for landfilling and discomfort with pressing GE to consider destruction technologies became crystal clear when it challenged our attempts to raise thermal desorption before the Environmental Appeals Board. And Region 1 continues to misrepresent the success of thermal desorption.

Considering the clear success of thermal desorption, we urge EPA to embrace treatment. Treat. Don’t Dump.

I’m extremely sad and disappointed that no one offered me, and you, the opportunity to weigh in on a settlement that will affect all of us and our descendants for decades to come before the decision was made, not after.

You may think my dreams for Rising, my dreams for a fishable, swimmable Housatonic are just delusions. You might be right — that taking $1.5 million makes more sense than a dream. But I have spent decades learning and caring about this. And I believe Rising Pond can be cleaned. I believe Rising can be restored after the cleanup. And the contaminated sediments and bank soils of Rising can be remediated and treated effectively.

This is why I am going to continue to fight for Rising.


Mickey Friedman is a writer and filmmaker and occasional opinion writer for Berkshire Record. Whatever objectivity he might have had about these issues vanished when he first talked to GE workers who, without proper protection, worked up to their elbows in PCB oil, and when he first learned that ducks who visited the Housatonic had the highest level of PCBs in the entire duck universe. You can better understand his bias by watching “Good Things To Life” on YouTube: https://www.youtube.com/watch?v=ACN6CpMqt1w. He was a founding member of HRI but left the board years ago to lend his Don Quixote-like efforts to ending never-ending wars and abolishing local hunger. He has occasionally been hired for peanuts to write and research for HRI. And because life is complicated, he also worked for GE Plastics.


For more information:

“Landfill Liner Failure: An Open Question for Landfill Risk Analysis”
Alberto Pivato
Journal of Environmental Protection, 2011, 2, 287-297
“The long-term durability of containment systems are to date unproven as landfill liner systems have only been used for about 30 years. Many recent studies have drawn attention to some of the deficiencies associated with artificial lining systems, particularly synthetic membrane systems. Consequently, failure modes of landfill liners need to be quantified and analysed.”

“Landfill Failures the Buried Truth “
Center for Health, Environment & Justice PUB 009
June 2015

Description of Danang Thermal Desorption process: https://www.usaid.gov/vietnam/environmental-remediation-process

Read the final report of the Danang remediation: pa00tds3 Danang

U.S. Vietnamese Embassy press conference

Read the 2020 Rest of River negotiated settlement agreement: 643538 Settlement Agreement PDF


1982 EPA Case Study: Housatonic River Massachusetts – Connecticut.