The Hudson River

PCB Cleanup –

Photo courtesy of Clearwater

A Light at the End
of the Tunnel In all its glory, the replica sloop Clearwater sails the Hudson River Valley
on its mission to educate the public about the river’s history and environ-
by Manna Jo Greene mental challenges.

t’s been a very long time coming, but there’s finally some Lower chlorinated PCBs are more water-soluble than more heavily

I measurable progress in the Hudson River PCB remediation

project. The problem of PCB contamination has dominated the
Hudson River Valley for more than 40 years. Listed under the
Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) on the National Priorities List in 1984, this
chlorinated forms. Some congeners are arranged in a coplanar
pattern while others are rotated into non-coplanar configurations,
each having different properties and effects.
PCBs are hydrophobic, moving out of water by adhering to sand, silt
or decaying organic debris. Because of this, they are relatively easily
200-mile stretch of Hudson River is one of nation’s largest Superfund filtered from water and eight municipalities take their drinking water
sites. After much negotiation and litigation, in 2002 the US Environ- from the Hudson River. They include the City of Poughkeepsie, the
mental Protection Agency (EPA) issued a Record of Decision (ROD) Towns of Lloyd, Esopus and Rhinebeck, and New York City’s backup
requiring General Electric (GE) to remediate PCB-contaminated water supply at Chelsea – all located below the Troy dam; as well as
sediment “hot spots” along a 40-mile stretch of the Upper Hudson, Waterford and Halfmoon, both located in the Upper Hudson.
north of the Federal Dam at Troy. Since then, the remedial design PCBs also are lipophilic – they tend to be stored in fatty tissue and
process has proceeded slowly, often tediously, but there is now are highly persistent. They are only minimally metabolized and can be
tangible progress with dredging scheduled to begin in 2009. harbored for a lifetime in the body. They bioaccumulate in the food
To become familiar with the issue of PCBs in the Hudson, extensive chain and can be a million times more concentrated in fatty tissue of
background information can be found on the EPA’s Hudson River top predators, where they are found several orders of magnitude
Superfund Site website: www.epa.gov/hudson; the Clearwater website: greater than in the blood. They also have an affinity for lipid-rich
www.clearwater.org/pcbs/index.html; or Scenic Hudson's website: brain and nervous system tissue.
www.scenichudson.org/whatwedo/resourcecenter/pcbs. General Electric used PCB as insulating oil in the manufacture of
electrical capacitors at plants located at Hudson Falls and Fort Edward
on the Hudson River, and in transformers manufactured in Pittsfield
along the Housatonic River, as well as in many other facilities across
the US. The EPA estimates that 1.3 million pounds of PCBs were
actively discharged by GE from both Upper Hudson plants into the
river between 1947 until 1977, when the compounds were banned
under the Toxic Substances Control Act (TSCA). When the Clean
Photo courtesy of Clearwater

Water Act of 1972 required GE to limit, then lower, its discharge, GE

was permitted continued use of PCB oil to flood-fill capacitors until
1977. Plant workers handling this equipment wore no gloves or other
personal protective gear and were reminded only by posted signage to
wash their hands before eating.
Even after 1977, PCBs continued to leak from a failing under-
ground storage tank into the fractured bedrock under the Hudson
GE manufacturing plant at Hudson Falls is one of two cited from which
1.3 million pounds of PCBs were discharged into the Upper Hudson Falls plant, and from outfalls near the Fort Edward Plant, and were
River for over 30 years until banned in 1977. released by erosion of remnant deposits. These sources of PCB are
currently being addressed under the site remediations overseen by the
Uses of PCBs New York State Department of Environmental Conservation
The 209 related chemical compounds, or congeners, of polychlori- (NYSDEC), but PCBs have not yet been removed from the Hudson
nated biphenyls (PCBs) were used industrially in various mixtures River itself.
trademarked Aroclors. In addition to being used as dielectric fluids
(insulating oil), PCBs were historically used in the first carbonless Making Matters Worse
paper and in various adhesives and caulking compounds. One con- In 1973, a former hydroelectric dam at Fort Edward was
gener, IUPAC-11, is a by-product of pigment that is not yet banned, determined to be unsafe and was removed. Large volumes of PCB-
although its manufacture was recently discontinued from a facility contaminated sediment up to 18 feet in depth, which had
along the Hudson.

Summer 2008 / Clearwaters

continued on page 2
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accumulated behind the dam, were released upon its removal – Environmental Health and Toxicology Division of the University of
rapidly dispersing over a 40-mile distance to the Federal Dam at Troy. Albany School of Public Health, cites additional studies showing
Following the hydrodynamics of the river, this contaminated material dose-related responses for diabetes and cardiovascular disease and
settled into a series of “hot spots,” which are now targeted for dredg- possible correlations with arthritis and intervertebral disc disease.
ing. With hindsight it is now clear that reinforcing the dam, rather While eating contaminated fish is the major route of exposure,
than removing it, would have limited the spread of contaminated dermal exposure and inhalation of PCBs that have volatilized into
sediment and greatly reduced the estimated $600 million cost of air, are additional pathways. PCBs are stored in fatty tissue and bio-
remediation, which GE will bear. accumulate in the food chain. In Our Stolen Future, Theo Colburn,
Until the PCB sediments are actually removed from the Upper Dianne Dumanoski and John Peterson Myers estimated that PCBs in
Hudson, it is estimated that 500 pounds each year wash over the Troy top predators, such as eagles, gulls and other fish-eating birds, can be
dam to the Lower Hudson, which is also part of this 200-mile as much as 25 million times greater than concentrations found in
Superfund site; however, this section of the river will not be included algae at the bottom of the food chain.
in the remediation. Any additional costs for disposing of contaminat-
ed sediment removed from the Lower Hudson for navigational
purposes will be incurred by municipalities, the NY/NJ Port Authority,
and local marina and dock owners.
The collapse of a wooden gate at the Allen Mill at the Hudson Falls
plant in 1991 added to the concentrations of PCBs in the Upper
Hudson. This structure had diverted water that contained oil-phase
PCBs from flowing into the Hudson. After its collapse, GE had
removed approximately 45 tons of PCB oil and sediment that had
leaked from fractured bedrock into a tunnel under the plant, with
NYSDEC supervision from 1993 to 1995.

EPA Actions
After EPA’s initial assessment and a “No Action” interim decision in Fish consumption advisories, and catch-and-release fishing is the rule for
1984, a 1989 Reassessment, which led to a Remedial Investigation/ much of the Upper Hudson.
Feasibility Study, ultimately resulted in the 2002 Record of Decision
(ROD). During the Reassessment, GE attempted to avoid a cleanup by As early as 1975, the NYS Department of Health issued health
engaging in a public relations campaign and a series of legal battles, advisories to limit consumption of fish from the river due to PCBs. In
which were estimated to cost somewhere between $60 and $100 1976, the NYSDEC banned all fishing in the Upper Hudson and most
million dollars – approximately one-tenth to one-fifth of the project- commercial fishing, including striped bass fishing, in the Lower
ed cost of remediation. The 2002 ROD called for a phased-in cleanup, Hudson, which has lower average PCB concentrations than are found
with an assessment of Phase 1 to be completed before Phase 2 is imple- above the Federal Dam in Troy. There is now a catch-and-release
mented. GE can opt out of the remediation for Phase 2, if they policy in the Upper Hudson to allow recreational fishing without
choose; however, EPA could then complete the cleanup and charge its consumption. There is an “eat none” fish advisory for all fish for chil-
cost, with triple penalties, back to GE. It also called for out-of-state dren under 15, and for women of childbearing age for the entire river.
disposal after earlier attempts to site landfills for contaminated dredge It is an “eat none” for everyone above the Troy dam. Below the Troy
spoils were deemed unacceptable in this region. Clearwater and other dam, it varies from one fish meal per month to one fish meal per week
environmental organizations called for contained facilities to for adult males.
prevented volatilization (evaporation) of PCBs from sediments to air, Global Transport: The story of Hudson River PCBs is a classic case
which was partially incorporated into the present design. They also of industrial pollution, once widespread in the United States, and
recommended treatment of the sediments, as opposed to disposal in increasingly a problem today in developing countries such as China.
hazardous waste landfills. The EPA, however, did not require treat- In the absence of the “precautionary principle” that prohibits chemi-
ment (other than basic dewatering) so the contaminated material will cal discharges until their safety is assured – pesticides such as DDT,
be shipped out of the Hudson River ecosystem to hazardous waste PCB, dioxins, and many other persistent organic pollutants (POPs)
landfills in Texas, where it will be stored indefinitely. and heavy metals have been distributed by oceanic and atmospheric
Health Effects of PCBs: As early as the 1930’s, chloracne rashes transport across the globe. In 1987, Dr. Eric Dewailly went to the
appeared in workers and in their families who came into contact with northern Canadian Arctic seeking a control group for research about
PCBs on workers’ clothing. A 1937 study published in Journal of PCB levels in the breast milk of mothers in southern Quebec, near
Industrial Hygiene and Toxicology by Harvard researcher, Cecil K. contaminated sites along the St. Lawrence River. Dewailly was aston-
Drinker, indicated PCBs cause liver tumors in rats. PCBs are now ished to find that PCB levels among Inuit mothers living in this
known to be probable human carcinogens, to cause skin irritations, pristine region, far from any industrial sources of pollution, were five
developmental effects including low birth weight, neurological times higher than women in the south. PCBs in the Arctic are also
disorders, including lowered IQ and poor short-term memory, as well partly responsible for the decline of the polar bear, due to endocrine
as hormonal disruption and suppressed immune response. In Japan disruption causing reproductive failure (Colburn, Dumanoski
and Taiwan, hundreds of people were exposed to PCB-contaminated and Myers).
rice oil in 1968 and 1979. Children born to women up to seven years More than 50 percent of the PCB-containing sediments that affect
after the incidents showed developmental delays and behavioral New York Harbor have been shown to originate from GE’s Upper
problems. In addition, Dr. David Carpenter, professor at the continued on page 3

Summer 2008 / Clearwaters 2

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Hudson facilities. This poses an ongoing challenge to the New GE has moved quickly and efficiently to implement the construction
York/New Jersey Port Authority to maintain navigation for large project on a 114-acre site owned by D.A. Collins along the Champlain
commercial shipping vessels. Canal, from which they will conduct one of the largest environmental
Remediation and Restoration: Remediation refers to the removal cleanups ever undertaken in the United States.
of PCBs from the environment. However, a parallel process, also The treated water, from which PCBs have been removed by sand
required as part of CERCLA, looks at the damages that PCB contam- and charcoal filtration, will be returned to the canal. The dewatered
ination has caused to natural resources and those who benefit by sediment, called filter cake, will be stored with coarser material
them. The Natural Resource Damage Assessment (NRDA) Trustees, (stones and cobbles) in separate covered containment areas near a
who oversee the assessment, include the NYSDEC, the US newly constructed rail spur off the Canadian Pacific rail line, where it
Department of the Interior/US Fish and Wildlife and the US will be loaded with the dredged debris into rail cars and shipped to a
Department of Commerce/National Oceanic and Atmospheric lined hazardous waste landfill in Andrews, Texas for burial. The rail
Administration (NOAA). Once their assessment is complete and facility is expected to accommodate 81 rail cars every two and a half
damages have been determined, the Trustees will file an NRD claim days. GE is conducting and paying for the work, with EPA oversight.
against GE to restore damages and lost resources – either through As quickly as construction is progressing, the project has not been
monetary compensation or specific restoration projects. The NRD uneventful. During the preliminary site preparation and excavation,
Trustees and GE could settle the NRD damage claim at any time – contractors discovered multiple boxes of dynamite, which appear to
even prior to completion of the assessment. have been buried in the early 1900s during the canal’s construction.
The site was quickly secured and over a period of several weeks, 4,766
sticks of dynamite were carefully removed and safely burned by the
New York State Police Hazardous Devices Unit. Other than this
unforeseen situation, GE’s internal safety program has been rigorous,
with no reported accidents or incidents.
For a virtual tour of the site, visit GE’s website: http://hudson
dredging.com/, which is devoted to information on the remediation
An example of a clamshell project.
dredge that will be used to Preparing to Dredge: Once construction is completed and the
remove PCB-contaminated system is tested, sediment from carefully delineated areas along the
sediment from a series of
“hotspots” in the river river bottom will be dredged (mainly by sealed clamshell dredges),
bottom located in a 40-mile loaded onto barges and transported from the river through Lock 7 of
stretch of the Upper Hudson. the Champlain Canal to the processing facility. There the dredged
USEPA materials will be unloaded at a newly constructed wharf, sorted to
remove large pieces of debris and coarse sediment, and moved into a
contained dewatering facility for further processing.
Current Status of PCB Remedial Design After considerable dispute between GE and the EPA concerning
The project is now in the “remedial design phase.” During the dredging areas, GE’s Phase One Dredge Area Delineation (DAD)
the design phase, the EPA has been meeting with GE to develop report was released in February 2005, behind schedule. This
engineering and quality of life performance standards (evaluation postponed the start of the dredging until 2009 at the earliest.
criteria), intermediate and final remedial design reports, and a In January 2008, GE released its second Dredge Area Delineation
consent decree. The cleanup will employ environmental mechanical (DAD) report for Phase Two, the remainder of the project. As the
(sealed-bucket) dredging, rather than hydraulic suction dredging, as Poughkeepsie Journal recently reported: “General Electric has
many area environmental groups had recommended. It will also allow convinced federal Environmental Protection Agency officials it can
a significant amount of PCB-contaminated sediment to remain at the dredge less of the Hudson River and remove more toxic polychlori-
shorelines. After more than three years of negotiations, an October nated byphenyls [sic] from the river. EPA Project Director David King
2005 Consent Decree was issued, which allows GE to “opt out” of the said recently tests showed contamination was not as deep into the
cleanup after the first phase of the remediation is completed – with river bottom as first thought. That means less sediment has to be
only about 10 percent of the total volume of PCB-contaminated dredged out of any given spot, so the project can expand to cover
sediment removal accomplished. The remaining phase of the dredg- more of the bottom and capture more PCBs.”
ing is expected to take five years. Environmental groups, skeptical about this claim, have asked for
Throughout the remedial design, Clearwater, Scenic Hudson, technical assistance to look into the details. Members of the CAG
Riverkeeper, Sierra Club and others in the Friends of a Clean Hudson agreed. At this point, little can be done to influence the process, but
coalition have participated in the EPA’s Community Advisory Group questions are still being raised with hope they will be addressed with-
(CAG), along with representatives from upriver municipalities, out slowing the progress of the remediation project.
unions, farmers, tourism, and other interests. Navigational Dredging Remains a Concern: Dredging conducted
Siting and Building the Dewatering Facility: It is necessary to by the NYS Canal Corporation, which was required to maintain
remove most of the water from the dredged sediment before shipping navigational channel depths in the Upper Hudson, had ceased in
and disposal. After narrowing the field from 24 possible dewatering 1979 due to the presence of PCB contamination. Under the Record
sites, a final site was selected in December 2004. The dewatering facil- of Decision, GE is only required to undertake environmental dredg-
ity is located in Fort Edward, near where a bulk of the contamination ing to remove the PCB-contaminated sediments, for which they are
is found. In April 2007, the EPA’s Community Advisory Group toured responsible. However, it makes no sense for GE to perform the
GE’s Hudson River Transportation and Sediment Processing Facility. continued on page 4

Summer 2008 / Clearwaters 3

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required environmental dredging and then restore habitat-
supporting conditions, only to have this disturbed later when the
Canal Corp resumes navigational dredging. It would be much more
efficient to do both environmental and navigational dredging under
the present remediation – ideally using some of the same equipment
and treatment facilities. Currently, these negotiations are in the hands
of the Hudson River Natural Resource Damage Trustees, who are
trying to reach an agreement with GE, but no progress has been
reported to date. This remains a major concern for all the members
of the CAG.
Through all the push-and-pull, the Hudson River CAG continues to
monitor the progress of the remedial design, as it will the actual PCB
cleanup. While pushing for the process to be as rigorous as possible,
the CAG desires to minimize any negative impacts on local
communities or the river itself.

Manna Jo Greene is the environmental director for Hudson River Sloop

Clearwater, Inc., located in Poughkeepsie, NY. The organization is known
for its sailing vessel, the sloop Clearwater, and its activism to raise
awareness for cleanup of PCB contamination of the river and watershed
issues of the Hudson Valley. Greene may be contacted at: mannajo@
clearwater.org or 845-454-7673, ext. 113.

NYWEA
LEADING THE WAY IN
WATER QUALITY MANAGEMENT

Summer 2008 / Clearwaters

Reprinted from Clearwaters magazine, Summer 2008 edition, with
permission by the New York Water Environment Association (NYWEA). 4
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