For many Rest of River residents advocating for a rail option to transport dredged toxic waste materials from the Housatonic River, the October 31 release by General Electric Company and its contractor, Arcadis U.S. Inc., was a disappointment. The document promoted truck transportation as the anticipated method for the majority of the 10- to 13-year project that seeks to clean up the Housatonic River.
The current remediation plan, approved in 2020 by the Environmental Protection Agency following years of GE depositing the now-banned polychlorinated biphenyls (PCBs) into the waterway from its Pittsfield plant, allows the most toxic material to be routed out of the area, off site, while the less toxic materials will be disposed of at an Upland Disposal Facility (UDF) in Lee. The Rest of River portion of the project spans downstream of the confluence of the east and west branches of the Housatonic River to Connecticut.
The program is divided into sections, or reaches, with Reach 5A, from the Confluence to the Pittsfield Wastewater Treatment Plant, to be addressed first. Reach 5B runs from the Pittsfield Wastewater Treatment Plant to Roaring Brook, and Reach 5C runs from Roaring Brook to the start of Woods Pond. Reach 6 is Woods Pond, Reach 7 extends from Woods Pond Dam to Rising Pond, and Reach 8 is Rising Pond.
Here is what GE released as its “anticipated” transportation plan for PCB-laden materials dredged from the Rest of River reaches of the Housatonic River to the Lee UDF and out of the area.
Why is trucking preferred to transport most of the excavated materials to the UDF? Why not rail?
In analyzing transportation modes, GE stated that it settled on trucking for most of the on-site transportation reaches since the method is widely used to transport soil and sediment within remediation projects; is technically feasible; offers flexibility since trucks can easily access material-removal sites and staging areas; and trucks are readily available as they aren’t dependent on a schedule.
Reaches 5C and 6 are slated to include the use of hydraulics to pump the excavated materials directly to the UDF site, obviating the need for approximately 55,000 truck trips in those segments, per the release. However, the release states that this provision isn’t a certainty and is only available “if feasible,” with other options to be evaluated as a backup.
Railroad transport, which the Tri-Town Board of Health recently favored for the project, was evaluated by GE but fell short of its preferred method. The release opined that other railroad traffic could delay or stop the remediation schedule; trucks would still be needed to transport some materials from the dredging or staging areas to the rail loading areas and then from the offloading area to the UDF; and rail would discount the use of a hydraulic system in reaches where it could be implemented, resulting in added truck trips. Additionally, a large discourse was given in the release to the availability of effective railroad siding—used to place the railcar so the material could be off-loaded into a truck. According to the document, the availability of usable railroad siding is limited near the removal or UDF areas, and upgrading the existing siding systems would not be efficient. “There are currently no usable railroad sidings available in or in proximity to the City of Pittsfield or the Towns of Lee, Lenox, Great Barrington and Stockbridge,” the release states.
For Reaches 7 and 8, since hydraulic transport to the UDF isn’t feasible, GE will present the option of rail or truck “at a later time in subsequent design documents.” That determination is dependent on the availability of and locations for transferring the material from the truck to railroad, the ability to offer an offloading site near the UDF and comparing the distance of trucking the material from the staging or removal areas to the UDF versus to the railroad siding loading areas, the release stated. According to timelines released for the project, these reaches may be years down the road.
What methods are anticipated to transport excavated materials off site or out of the area?
Once again, GE relies on the wide use of trucking for toxic waste projects as support for its anticipated use in the upper reaches of the Housatonic River’s remediation as well as the mode’s flexibility.
Another option would involve trucking the material to an existing off-site commercial rail loading facility in Albany or Worcester to be loaded onto trains. Again, GE points out that this option still involves local truck travel from the excavation site. “Thus, it is anticipated that both truck and railroad modes of transportation would require the same number of truck trips, although the distance and routes of the trips would differ based on the selected mode of transportation,” the release states.
How many trucks are projected to travel down Berkshire County roads during the project?
For on-site disposal, the release shows that the trucking option anticipates a total of 32,000 truck trips for all reaches for the project duration, with Reach 5A accounting for 12,200 trips total, 3,100 trips annually, and 15 trips daily. Reach 5B accounts for 1,300 trips total and for one year, with seven trips daily. Reach 5C accounts for 1,300 trips total, 440 trips annually, and two trips daily. Reach 6 accounts for 60 trips total, 20 trips annually, and less than a trip per day on average. Reaches 7 and 8 account for 17,300 trips total, 5,800 trips annually, and 29 trips per day. According to GE, those numbers double for rail use as trucks would still be required to transport material from the removal or staging areas to the rail areas and then to the UDF, for a total of 64,000 truck trips for all reaches during the entire project.
For off-site disposal, the release shows that the trucking option anticipates 7,000 truck trips for all reaches for the project duration, with Reach 5A accounting for 640 trips total, 160 trips annually, and one trip daily. Reach 5B accounts for 150 trips total and for one year, with one trip daily. Reach 5C accounts for 2,900 trips total, 980 trips annually, and five trips daily. Reach 6 accounts for 2,200 trips total, 730 trips annually, and three trips per day on average. Reaches 7 and 8 account for 1,600 trips total, 530 trips annually, and two trips per day.
Although the release states that rail transportation of material off site would reduce truck traffic by a minimum of 100,000 cubic yards of material, railroad siding would still be needed, presenting issues of availability, location and reconditioning. Trucks would continue to be required to transport material from staging or removal areas.
What roads will be used to transport excavated materials, onsite and offsite?
The newly released plan for the Rest of River outlines and maps anticipated truck routes for both on-site and off-site disposal (see attached) in each reach of the project, with a statement that the details of the later reaches are to be finalized in subsequent documents.
Per GE, the on-site disposal routes were chosen to avoid designated restricted roads and are in less densely populated residential and commercial areas than roads in other more developed neighborhoods.
For on-site disposal, anticipated routes include:
- Reach 5A — Trucks would travel on temporary access roads to Holmes Road, cross the river on New Lenox Road, and then use Roaring Brook Road to get to staging areas on the western side of the Housatonic. For the eastern side staging areas, the route would include temporary access roads to East New Lenox Road, then Roaring Brook, with both sides continuing to Roaring Brook and Woodland Road to the UDF.
- Reach 5B, 5C, 6 — Trucks would travel south to the UDF via Reach 5A routes. For staging areas on the western side of the Housatonic, trucks would cross the river on New Lenox, turn right on Roaring Brook to the UDF. For staging areas on the eastern side of the Housatonic, trucks would travel down Roaring Brook to Woodland.
- Reach 7, 8 — Trucks transporting material removed north of I-90 would use either US-20 to access the western side of the Housatonic or Columbia Street to Mill Street for the eastern side of the Housatonic, with both routes using Willow Hill Road to reach the UDF. Trucks transporting material removed south of I-90 and Reach 8 would use MA-183 or Route 7 to Walker Street to Willow Hill.
GE stated that the company is currently looking at an alternative to using Willow Hill, a route that local residents have objected to at various meetings with the EPA, and, per the release, is seeking permission from a property owner for an access easement. The company said it will evaluate the roads to be used in the transportation process to determine the level of reconditioning or upgrading needed to sustain the truck traffic, as well as “the habitat/ecological impacts of road reconditioning or upgrades.”
As with the selection of the on-site disposal routes, the off-site disposal routes were chosen to prioritize major roads, avoid designated restricted roads, and bypass other local roads through developed areas.
For offsite disposal, anticipated routes include:
- Reach 5A — Trucks would travel west via US-20, with trips from the staging areas on the western side of the Housatonic heading north or south on Holmes to US-20, possibly connecting through Pomeroy Avenue to Crofut Street, while trips from the staging areas on the eastern side of the Housatonic would take East New Lenox to New Lenox to US-20 to the interstate system.
- Reach 5B — Trucks traveling from the eastern side of the river would take New Lenox, heading with trucks from the western side of the Housatonic down US-20.
- Reach 5C — Staging areas are anticipated to be on the eastern side of the Housatonic, with trucks traveling north to New Lenox to US-20. Some traffic may travel south on Roaring Brook, crossing the Housatonic on Mill and traveling on Walker to US-20.
- Reach 6 — Trucks would travel from the staging areas via Walker to US-20 to I-90.
- Reaches 5C and 6 hydraulic system — Trucks would transport materials hydraulically removed to the UDF. However, if at the UDF it is determined that the materials are destined for off-site disposal, trucks would travel via Walker to US-20 to I-90.
- Reach 7, 8 — Trucks traveling from areas north of I-90 would use US-20 to I-90 West. Trucks from areas south of I-90 and Reach 8 would travel east on MA-102 or MA-183 north to MA-102 West to I-90 in New York. An alternate truck route to I-90 includes MA-183, south to MA-102 West to I-90 in New York.
“Designated restricted roads” are exempt from the truck routes and, according to EPA officials during a November 1 meeting with the Tri-Town Board of Health in Lee, were created within the sessions that developed the 2020 permit; that is, non-public meetings with representatives from Great Barrington, Lee, Lenox, Sheffield, and Stockbridge.
Both onsite and offsite route maps show the potential use of Glendale Middle Road in Stockbridge.
Additionally, staging areas will be used for the temporary handling of materials for transportation, with those non-GE property sites confirmed after the final design is determined and before site work begins. Tract owners of the proposed staging sites will be requested by GE to sign a Consent for Access form to allow the company and agency personnel admittance.
Which excavated materials will go to the UDF in Lee and which to an off-site facility?
The determination of which dredged materials will be transported to the UDF or to an off-site disposal facility will be made at the work site and assessed according to criteria that includes the PCB concentration within the removed materials, the release states.
The Lee UDF will include only Rest of River-generated remediation materials, and no material from the Rest of River site is to be disposed of at any other Berkshire County location.
According to the document, an estimated 1.03 million cubic yards will be removed from Reaches 5A through 8, with 933,000 cubic yards disposed of on site, and 100,000 cubic yards disposed of off site.
How will the excavated and transported materials be handled? What safety measures will be taken?
The release provides that documentation relevant to how the site-related material will be handled, including procedures for potential spills of the contaminated substances, will be submitted to the EPA by GE by January 25. Generally, the removed materials will be loaded directly onto “sealed vehicles” and taken to the staging areas, where they will be stockpiled and dewatered by gravity before being transported to the Lee UDF or to another off-site disposal facility. Some dredged debris may be decontaminated, such as a boulder that is power washed, and reused, the document states.
For both on-site and off-site transportation, the trucks will be lined with polyethylene sheeting and the excavated material load covered, with additional safety checks as the truck leaves the staging area for the UDF or railroad siding. Additionally, GE’s release states that it is requiring the transportation contractor to use personnel trained in hazardous material shipping; use drivers with a Hazardous Materials Endorsement on their Commercial Driver’s Licenses; use U.S. Department of Transportation-inspected and -certified trucks; keep records of the number of truck loads taken to the UDF; and confirm the materials are “suitable for transport” and don’t contain free liquids. Details for responding to transportation emergencies will also be provided. The loads will be documented throughout the process, and each container will be marked signifying that it holds PCB materials, with trucks marked to be in compliance with state and federal regulations for the carrying of hazardous substances. The contractor will also be tasked with counting the volume of the material going into the UDF.
If rail is used as transportation to the UDF along with trucks, the same procedure will be in place.
Once at the UDF, the release states that the material delivered by truck or rail will be graded and compacted. The material sent by hydraulic measures will be dewatered and compacted, with the resulting liquid later treated and disposed of.
Although the release states that “potential offsite disposal facilities have been identified,” including landfills outside of Massachusetts, it doesn’t provide the specific facilities identified.
What’s next?
The communities involved in the remediation project are given 90 days to provide comments to the EPA on the transportation plan, with a November 28 informational session scheduled in Lee with GE representatives. Within the allotted time, the agency can reject, accept, or return the transportation plan back to GE to incorporate its changes to the document.
According to the release, the transportation plan was determined after communicating with municipal officials on their preferences for potential travel routes, with proposed routes changed following these discussions. But nothing is set in stone yet. “Additional efforts are still being made to coordinate with property owners and municipalities to further identify potential travel routes,” the document states.
Further, a Quality of Life Compliance Plan—that includes impacts from the transportation and disposal methods—is due from GE to the EPA on December 20. That plan will address traffic concerns in the residential areas and stress on local roads from the anticipated trucks, with an eye toward actions that could minimize those negative impacts.
Comments and public input on the plan is due Feb. 1 and should be sent to R1Housatonic@epa.gov.
