summer 1999 newsletter - special edition
TO TREAT, OR TO DUMP? THAT IS THE QUESTION
1/2 of Jack Welch's salary can pay for treating PCB soils and sediments and prevent a toxic dump across from the Allendale School: what price a playground? a rug for the river?
As a result there will be two adjacent very large containment areas (dumps) on already contaminated GE property, at the existing dump on Hill 78 and at Hill 71 across from the playing fields of the Allendale School.
As you read this the United States Environmental Protection Agency (EPA), the Massachusetts Department of Environmental Protection (DEP) and the General Electric Company (GE) have decided how, and to what extent, the first half mile of the Housatonic River will be cleaned. While they debated certain things like what levels of PCBs will remain after the clean-up, and whether or not GE could put a geotextile cap or rug in the river, they have decided not to treat the PCB- contaminated sediments of this section of the river and PCB-contaminated soil from the river bank. So, for the moment, the answer to the question is: to dump! to dump! to dump, and dump some more!
TO DUMP
For those of you who live in Pittsfield far enough away from the site, you might say, "Hey, it's got to go somewhere! That's the best place for it. It's already poisoned." For those of you who live in Lenox, Lenox Dale, Stockbridge, Lee, Great Barrington, and Sheffield, you might say: "Well, at least they're finally getting around to cleaning some of the river." Yet, for those who live, or work near the 11-acre, or send their kids to Allendale, it's an unnecessary tragedy. And, the fact of the matter is, the rest of us need to do whatever we can to make sure this doesn't happen.
According to the EPA, this dump is a done deal. This is the best place for it! Hill 78 is already contaminated, and the other sections of the GE property are slated for redevelopment. And there's no point putting a dump next to a new business. So the current plan is to put PCB-contaminated material less than 50 ppm* (parts per million) on top of the existing dump at Hill 78, and create a new landfill for high-level contaminated materials above 50 ppm in nearby Hill 71.
EPA PUBLIC MEETING - 5/18/99
In describing the Hill 78 landfill, Bryan Olson, the EPA Project Manager stated: "One of the main reasons why we chose ... the Hill 78 site is that it is an existing landfill - it's a landfill that contains high levels of PCBs, probably much higher than we're going to be putting in there, and you can't remove it, it's not the kind of project that anyone does - you don't remove landfills, you can cause many more problems by doing that, than just by capping it and leaving it in place ... from a risk standpoint you can use it, we have parks on top of landfills in other parts of the country in similar situations to this one." (emphasis ours)
So, the reasoning goes, Hill 78 is already contaminated, and the EPA and DEP have no intention of cleaning it up, so why not add more contamination on top of it. And because it's an old dump without any kind of protective liner on the bottom, the EPA is only going to add lower levels of contamination, less than 50 ppm, on top of the old contamination.
The higher-level contamination is going to be put in the new lined landfill right next to Hill 78 in Hill 71. And to better ensure it's safe, the EPA is going to make sure the very worst contamination isn't allowed. In describing the Hill 71 landfill, Bryan Olson said: "We're not going to allow any liquids ... we're not going to put in any drums, any transformers, any capacitors, or anything like that ... "
Making sure there are no liquids, helps to ensure that the bottom liner and the cap on top will keep the contamination from moving back into the environment. Olson continued: " ... as long as there's no liquids in there, it doesn't matter what ... the concentration is because we'd be doing the same thing, the same kind of protective cap and liner system."
To many in the audience, this logic didn't make much sense. Members of the public and HRI members kept reminding the EPA and DEP regulators that the existing Hill 78 was already filled with exactly the kind of toxic materials that the EPA wasn't going to put in Hill 71 because they were dangerous: including barrels and barrels of PCB-contaminated liquids, contaminated fullers earth, solvents, and probably metals, the worst kinds of high-level, dangerous wastes. People stressed that what the regulatory agencies were doing, by adding tons and tons of more waste on top of Hill 78, was just going to make potential problems of leaking barrels that much more difficult to deal with.
Bryan Olson's response was that: "we have monitored this landfill ... for a fairly long time and we don't see any impacts from the landfill, going away from the landfill." In response to Nanci Bertelli's testimony that GE workers reported barrels being dumped at Hill 78, Olson stated: "we're expecting that they're probably drums in that landfill, but we think that the solution will work no matter what's in the landfill." HRI Board Member Benno Friedman then raised the question of why the DEP was making the City of Pittsfield spend $1,500,000.00 to remove hundreds of barrels of contaminated GE waste from the city landfill a mile away from Hill 78? Wasn't it because they regarded these buried barrels as a significant environmental and human health problem?
And wasn't the EPA turning its back on a potentially worse problem across the street from a public school? Doesn't it makes sense to check for barrels, and get them out of Hill 78 before you bury them even deeper. Ultimately, Bryan Olson said the agencies would think about checking Hill 78.
A quick trip, several days later, to the repository at Simon's Rock where EPA and DEP and GE documents are stored, revealed the following information from the 1988 EPA Site Assessment: "Building 78 Landfill - The unit was formerly a ravine which has been filled with waste material. ... Former employees stated in an interview that drums and liquid containing 'Pyranol' were disposed in the landfill in the 1950s and 1960s. Pyranol is composed of 60% PCBs. Sampling of the fill has revealed some areas with PCB concentrations at several hundred ppm. ... DEQE [the Mass. Department of Environmental Quality and Engineering - which preceded the DEP] suspects an oil layer exists in the landfill. Former employees stated PCB-containing liquids were poured on the ground."
It only gets worse. An APRIL 1994 Public Involvement Plan document by the Massachusetts DEP states: "The Hill 78 landfill is approximately two acres in size with a maximum depth of approximately 40 feet. ... The school property is within 50 feet of the Hill 78 site fence line. From approximately 1940 to 1980, GE used the Hill 78 area as a landfill for demolition or construction debris, excess fill and solid (reportedly non-hazardous) waste. GE also allegedly used the landfill to dispose of drums containing PCBs and fuller's earth saturated with PCBs in the 1950s and 1960s.
The EPA RCRA Facility Assessment stated that former GE employees disposed of PCB oil in the landfill. From 1980 to early 1990, GE used this area to store soils containing less than 50 ppm PCBs from routine, facility-wide excavations. Sampling of the fill revealed areas with PCB concentrations up to 120,000 ppm in subsurface soil." (emphasis ours)
"Investigations in this area conducted prior to 1989 were completed on behalf of GE... Most of the soil sampling was completed to determine the extent of contamination in the proposed Altresco plant construction area. The location selected for the Altresco plant generally contains less than 1 ppm PCBs, except for the northern portion of this area, where concentrations as high as 16,000 ppm were detected at a depth of six feet." (emphasis ours)
"Oily sheens were present on two of the soil samples from the fill. The fill extends at least 25 feet below the ground surface. Subsurface soil at the site is contaminated with PCBs at concentra-tions up to 120,000 ppm and VOCs were present in soils at concentrations of less than 1 ppm. Ground-water samples were collected from the four wells and analyzed for VOCs, SVOCs, PCBs and inorganics. Results indicated the presence of phenols at 75 ppb.
In 1991, GE's consultants completed a Phase I investigation of the site. ... Results confirmed that the landfill area is the most contaminated portion of the site. Ground water in the vicinity of the landfill area is conta-minated with PCBs at concentrations up to 9 ppb. In addition, VOCs were detected in ground-water samples collected from wells located downgradient of the landfill area and south of the Altresco power plant at concentrations of less than 1,000 ppb. Ground-water samples collected from a well in the southwestern corner of the site contained concentra-tions of less than 30 ppb of dioxins and furans. The Department classified the site as a priority and GE submitted Phase II Scope of Work proposing further definition of ground-water contamination at the site and assessment of contamina-tion potentially attributable to abandoned transformer oil lines extending from the East Street Area II site across this site and to Building 51 (part of the Unkamet Brook site). (emphasis ours) And then from the DEP's Public Involvement Plan, Volume 5, Page 12: Table 1: Descriptions and Characteristics of GE Pittsfield Disposal Sites: Hill 78 Landfill Area; 57 acres; DEP & EPA jurisdiction - Contamination: PCBs in subsurface soils (average concentration 498 ppm; maximum concentration: 120,000 ppm)
WHY?
So the questions remain: With all our experience with leaking dumps, why decide to expand a toxic landill across from a school? Why not make GE spend several million dollars and clean out Hill 78 the same way the City is removing PCB barrels from its municipal landfill? And why not insist that GE treat its wastes from the Housatonic River, the Allendale School, and the Newell Street properties? Why put public health at risk when one of the world's most profitable corporations can clearly afford to spend the money for treatment.
DUMPS & LINERS
Here's some of what other EPA scientists have said about landfills in the past: "There is good theoretical and empirical evidence that the hazardous constituents that are placed in land disposal facilities very likely will migrate from the facility into the broader environment. This may occur several years, even many decades, after placement of the waste in the facility, but data and scientific prediction indicate that, in most cases, even with the application of best available land disposal technology, it will occur eventually." (Federal Register, Feb. 5, 1981, pg. 11128)
"Manmade permeable materials that might be used for liners or covers (e.g., membrane liners or other materials) are subject to eventual deterioration, and although this might not occur for 10, 20 or more years, it eventually occurs and, when it does, leachate will migrate out of the facility." (pg. 11128)
"A liner is a barrier technology that prevents or greatly restricts migration of liquids into the ground. No liner, however, can keep all liquids into the ground. Eventually liners will either degrade, tear, or crack and will allow liquids to migrate out of the unit." (Federal Register, July 26. 1982, pg. 32284)
"Some have argued that liners are devices that provide a perpetual seal against any migration from a waste management unit. EPA has concluded that the more reasonable assumption, based on what is known about the pressures placed on liners over time, is that any liner will begin to leak eventually." (pgs. 32284-32285)
"Since disposing of hazardous wastes in or on the land inevitably results in the release of hazardous constituents to the environment at some time, any land disposal facility creates some risk." Federal Register, May 26, 1981, pg. 28315)
"The longer one wishes to contain waste, the more difficult the task becomes. Synthetic liners and caps will degrade; soil liners and caps may erode and crack ... EPA is not aware of any field data showing successful long-term containment of waste at facilities which have not been maintained over time." (pg. 28324) "First, even the best liner and leachate collection will ultimately fail due to natural deterioration, and recent improvements in MSWLF containment technologies suggest that releases may be delayed by many decades at some landfills. For this reason, the Agency is concerned that while corrective action may have already been triggered at many facilities, 30 years may be insufficient to detect releases at other landfills." EPA, Federal Register, August 30, 1988, Vol., 53, No. 168.
Joel Hirschorn, a consultant and advisor to local activists in Warren County, North Carolina who were concerned about their hazardous waste landfill, has written: "Data obtained from a 1983 EPA study showed conclusively that uncontrolled releases of PCBs into the air were occurring. Neither EPA or the state analyzed the data properly, and EPA made incorrect statements. In fact, the levels of PCBs found by EPA in the air near the landfill and in the yard of a residential house more than a half mile from the landfill were several times greater than the level of health significance in EPA's own risk assessments. ... An analysis of the only state documents referring to the 1983 study by EPA and the only information given to the public has shown that the state intentionally misrepresented the findings of the 1983 tests for PCB air releases from the landfill. For example, the highest levels of PCBs found at the landfill's main vent were not reported by the state, and the state indicated that no measurable amounts of PCBs had been found around the site, which was not the case. The state has persistently deceived the public about PCB air releases and, more importantly, the significant public health risks resulting from them." (emphasis ours)
And then, lo and behold, here at home in the Saturday, May 22, 1999's Berkshire Eagle comes the headline: "Levels of toxic vapors found in two West Main Street homes". The article stated that the DEP has found levels of toxic vapors of trichloroethylene, TCE, coming from the Sprague landfill in North Adams; and that TCE had leached into the groundwater at levels that could pose long-term health risks. Without a detailed search of the Hill 78 landfill, and a thorough cleanup we will have to wait until it leaks badly enough for the DEP and EPA to take remedial action. What happened to the buzzword of the 1990s - proactive?
TO TREAT
There's another way to solve this problem. A way which benefits us all. It's called treatment. And, although it's not perfect, it works. It worked in Lanesboro, when GE treated the PCB-contaminated soils at the Rose Landfill. It works in Canada, where GE Canada treats its PCB-contaminated waste. We're not saying treatment is perfect, but it reduces the massive quantities of contaminants, and removes the overwhelming bulk of them from the environment, leaving small quantities of liquid PCBs and large amounts of soil that is mostly detoxified and often used to cover landfills.
We have repeatedly asked for a series of pilot projects at the GE Pittsfield/Housatonic site to test the most promising treatment technologies. EPA and DEP have not been willing to grant our request. Instead, they have negotiated a solution in the "public interest" that relies on landfilling. Why won't they make GE treat its PCBs from the River, Allendale, and Pittsfield properties?
Did GE flat-out refuse to treat the contaminated sediments and soils of the first half mile because they didn't want to set a major precedent for the rest of the river, the Hudson, and their many dozens of other Superfund sites? Did they go into the negotiations stating they would refuse to sign any agreement if the EPA insisted on treatment?
Of course, we weren't at the table, and you weren't at the table, and this is the deal they made. If we had participated, we would have made the loud and constant demand for treatment. It's a great deal for GE. Why spend more money treating the PCBs, if you can bury them? GE isn't one of the richest corporations on earth because it spends money when it doesn't have to. And there must have been pressure from politicians in Boston, and Washington all of whom get campaign money from GE, telling the EPA to get the deal done.
But what about the people in Pittsfield who live near the dump? What about the school children and school staff who'll be spending many hours each day across from the unlined, anything but state-of-the-art Hill 78 dump? And what about the precedent it sets? You who live far away from Allendale may breathe easy today, but what about tomorrow, when the people of Lenox want Woods Pond cleaned? Or the river in Lee, Stockbridge, Housa-tonic? Will GE treat those wastes?
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