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HOW MUCH MONEY ARE WE TALKING ABOUT?
It's hard to get exact figures on the difference between treating and dumping. Because GE will be doing the transporting and the dumping, they seem to be the only ones who know exactly what their costs are. And they haven't released what it would cost if they treated, rather than landfilled. When we have asked the EPA for comparative figures for the clean-up of first half mile of the Housatonic, we were given an estimate based on their experience with the remediation at the Loring Air Force Base. There dumping on site costs $30 a ton, as opposed to $300 a ton to treat it. Treatment costs ten times as much as landfilling.
Let's do some calculating of our own. GE, in its draft Removal Action Work Plan - Upper 1/2 Mile Reach of Housatonic River estimates that "approximately 6,000 in-situ cubic yards of river sediment is currently targeted for removal" (page C-3). Add to that GE's estimate of bank soils: "A total of approximately 4,300 cubic yards of bank soils is currently targeted for removal" (page D-4). It comes to 10,300 cubic yards. One cubic yard is equal to a ton and a half; 10,300 cubic yards equals 15,450 tons. Multiply that by $300. The total is $4,635,000.
According to the Berkshire Eagle of April 9, 1999, Jack Welch, CEO of General Electric, doubled his annual earnings in 1998 to $83.6 million dollars. If the decision was left to you, would you rather have GE pay for treating its toxic waste or burying it beside a public school. Can GE afford $4.6 million? But, wait, the EPA says, it's not just the wastes from the first half mile of the river: there's the next mile and a half. Add the soil from the Allendale School, and the Newell Street cleanup. That brings the figure up to 100,000 cubic yards. Add a bit, just in case. It's about $46 million dollars to treat it and only $4 million to bury it across from Allendale.
$46 million dollars is a lot of money. More than half what Jack Welch makes in one year. Would you ask him to sacrifice that much money to treat GE's waste? EPA and DEP think that's too much to ask, too much to demand of GE. Putting that waste across from the school is absolutely safe. And it's their job to protect the public health and safety. But what if they're wrong? Who suffers from their mistakes?
REST OF THE RIVER
When it's time to clean the rest of the river, the Hill 78/71 dumps will be filled. If I were GE, I'd argue that since the EPA agreed to a dump in Pittsfield, they believe it's safe, they know it works, so let's landfill down in South County. And I'd refuse once more to treat any river contamination. GE will argue it's unreasonable to ask us to spend ten times the money to treat the river wastes of Lenox, or Stockbridge, or Lenox Dale, or Great Barrington, or Sheffield, when for 1/10th the price we can landfill it There's got to be a place to dump the stuff. You want the river cleaned, find us a place to put the PCBs!
So if you let them dump GE's poison near a school in Pittsfield, and you want your river cleaned, you better start looking for some large potential dumpsites down south. In keeping with the school motif, how about if the DEP and EPA put it across from Lenox High, or Monument Mountain, or maybe Searles School in Great Barrington? HOW BIG A DUMP? Well here's GE's guess as of a few years ago. Excerpts from: Proposal for the preliminary Investigation of Corrective Measures for Housatonic River and Silver Lake Sediment, Prepared for GE by Canonie Environmental, March 1995
"As discussed in Section 1.5, the in-situ volumes of sediment in the study area containing PCB concentrations greater than 1 ppm, 10 ppm, and 50 ppm have been estimated to be as follows (in cubic yards):
Housatonic River, - GE to Woods Pond: less than: 1 ppm | 10 ppm | 50 ppm 455,000 | 320,000 | 179,000 Woods Pond 200,000 | 95,000 | 58,000 Silver Lake 173,000 | 120,000 | 83,000 TOTALS: 828,000 | 535,000 | 320,000(Page 3-75.)
"Based on these estimates, a range of sediment volumes that might need to be dewatered and disposed of has been determined, along with the approximate size of the dewatering/disposal cells that would be required for these volumes (based on a 5-foot cell depth and a 10-foot berm), The range is as follows:
Volume | Dimen. of Cell | Acres 100,000 cy | 735 ft W x 735 ft L | 12 300,000 cy | 1,275 ft W x 1,275 ft L | 37 500,000 cy | 1,650 ft W x 1,650 ft L | 62 1,000,000 cy | 2,350 ft W x 2,350 ft L | 127 Page 3-76
So the way it works now is: the cleaner you want your river, the bigger the dump the EPA and GE will build. 12 acres, 37 acres, 62 acres. Or if you want the river cleaned to 1 ppm PCBs, how about 127 acres?
WHAT ABOUT A VOTE?
So what if we took a vote? What if every voter in Berkshire County could decide whether they would rather have GE spend $46 million dollars to treat the waste or build that eleven acre dump across from a school. And whether or not they want all of GE's contaminated sediments treated or landfilled. The only members of the public from Berkshire County allowed to participate in the negotiations were Pittsfield Mayor Doyle and City Council President Tom Hickey. What do you think? Do you think GE can afford $46 million to treat the waste from the first two miles of the Housatonic, from the schoolyard, and from Newell Street? Whose contamination is it, after all?
We say that before a decision is made, bring in the best clean-up companies and let them compete to see who can treat the wastes at the most reasonable cost. And compare that to the immediate costs of landfilling, the long-term costs of monitoring and cleaning up the mistakes we know will happen in the long-term. And then add in the social costs to the Allendale community. And the potential health costs.
LONG-TERM COSTS
What about the risks of failure in the dump system? EPA scientists have acknowledged those risks. Innocent Americans all over the country have experienced the pain and disease that comes from leaking landfills.
There is always risk. When GE has the money to remove and treat its poison, why should Pittsfield people have to live with that risk?
WHAT PRICE FOR A PLAYGROUND?
When the EPA and GE announced its agreement for this summer's cleanup of Allendale School, the agreement was applauded by Michael J. McCarthy, a parent and co-chairman of the Allendale School Council, who declared that GE "has agreed to go above and beyond what is required by the law and what is in the consent decree." He informed members of the Citizens Coordinating Council (CCC) that GE has offered to clean contaminated soils to 2 parts per million (2 ppm) without regard to averaging, replace the school's playground equipment, install a new running track, and a new soccer field. baseball field, and some park benches.
A pretty good deal, except for the small, nagging fact that kids, teachers, school staff, joggers, and outfielders will be right across the street from a large 11 acre less-than-state-of-the-art PCB dump.
TAKING RESPONSIBILITY
The designation of this 11-acre dump is a failure on all our parts. In our attempt to work constructively with the EPA and DEP, we assumed they would make a good faith effort to incorporate treatment. We were hoping for a negotiated settlement we could live with. And many of us got heavily involved in the river restoration issues that will follow the clean-up, trying to ensure that some of the settlement money for natural resource damages would be controlled by Berkshire residents.
As soon as we discovered what was happening, we began to ask hard questions and speak out. But we were hesitant to come out and be too critical because we didn't want it to appear that we were undermining the entire settlement. We want to support redevelopment of the GE facility. We want new jobs for Pittsfield. We want a clean-up for the river. And we kept hoping we could convince the agencies to change their minds about treatment.
That hard work gained us a small victory - and because of our efforts - the EPA has mandated a bottom-liner that GE didn't think necessary for the new portions of the Hill 71 landfill. But the more research we do, the less willing we are to accept that limited victory. The more we learn, the less able we are to live with the idea of a major landfill across from a school. They may not be our children, but they may be yours. Today, your children! Tomorrow, ours!
A SETTLEMENT WE CAN LIVE WITH
Other environmental and social organizations have fallen silent on this issue. If you support and contribute to local environmental, social, and religious organizations, ask them why they aren't speaking up about this unnecessary dump.
All of us who care about the environment, and care about a comprehensive river cleanup, must not forget that the students and staff at Allendale have played atop a toxic waste dump for too many years already. It's a hollow victory to have that contaminated soil trucked and stored a few hundred yards away. A toxic waste dump with flowers on top, is still a toxic waste dump.
NO RUG FOR THE RIVER
Let's turn our attention to the agencies clean-up strategy for the river. HRI has received no written response to two sets of technical comments it has submitted regarding General Electric's "Removal Action Work Plan - Upper 1/2-Mile Reach of Housatonic River" of January, 1999. While Bryan Olson and Dean Tagliaferro have said at public meetings that public concerns have been incorporated into EPA's response to General Electric's proposal, specifically that geotextiles will not be used as part of the remediation of river bank contamination - we are unable to see their detailed response to GE's plan or the decisions they have made about remediation levels, capping, and the supporting scientific and technical rationale behind those decisions.
Instead, even though the agencies' first brief summary comments about the Upper 1/2-Mile Reach came one week into the four week public comment period that ends June 6, 1999, we have been expected to respond to decisions we do not fully appreciate, or understand.
Nevertheless, here's some of what bothers us. HRI's comments regarding the Removal Action Work Plan - Upper 1/2-Mile Reach of Housatonic River focus on several major areas:
- 1) our concern that unnecessarily high levels of contaminates are being left unremediated
- 2) our concern that a geotextile liner will be placed above that unremediated and remaining contaminated layer of river sediment in an attempt to cover over contaminants that may, in later years, re-contaminate the river system
- 3) our concern that geotextiles have only been used for twenty-five years; and that there is disagreement among technical experts as to its efficacy in riverine systems
- 4) our concern that there has not been an adequate pilot test in situations similar enough to the Housatonic to justify its use
- 5) our concern that the agencies seem determined to allow GE to place contaminated river sediment and contaminated soil from the banks from the Upper 1/2-Mile Reach of Housatonic River into the existing, unlined hazardous waste dump 50 feet across from Allendale School
- 6) our concern that even though the costs of treating and removing the overwhelming bulk of the contaminated sediments and bank soils of the Upper 1/2-Mile Reach of Housatonic River from the local environment would cost approxi-mately $4,635,000 - a sum certainly affordable by General Electric - the agencies refuse to choose this remedy.
"It is the opinion of LEEI that these remedial decisions are based on entirely too little data, and that the data itself are highly questionable. Given GE's proposed plan to cap the remaining river sediment subsequent to excavation, we seriously question the benefit that such an exercise will have on the ecological systems and potential human receptors when compared to the disruption and uncertainties that the exercise will entail. ... It is also the opinion of LEEI that capping the sediment should be further evaluated as a remedial option before it is implemented over the entire 1/2-mile stretch. We have reviewed many articles on capping, including some cited in BBL's report.
According to one study 'capping is likely to be used only in environments where the long-term integrity of the cap can be guaranteed. Typically this would mean low hydrodynamic energy environments such as harbours, estuaries and lake bottoms.' ... It is the opinion of LEEI that the Work Plan should also involve a pilot test of a high velocity and scouring area before the cap is implemented over the entire 1/2-mile reach. It is our opinion that, rather than a prediction of PCB flux based on computer models (Appendix G of BBL's report), that GE be required to obtain actual data on flux and PCB concentrations using seepage meters placed at key locations on the river bottom. These data could then be used to calibrate the model to make more accurate predictions of the cap's useful life."
WE NEED A PILOT PROJECT
On February 11, 1999, at the request of HRI, the EPA brought their river remediation consultant, Mike Palermo, from the U.S. Army Corps of Engineers to address the Community Coordinating Council. He told us:
"I don't know of that many riverine sites ... rivers present a set of site conditions that are a little different say than an estuarine or open ocean type of site - you have different things to design for, for instance, flood events, or in this case, even ice, you know, formation and ice effects, but no, we have not seen caps constructed in many riverine situations."
In response to Benno Friedman's question about what it would cost to go back into the river to fix the cap in the event of cap failure, Palermo said: "Well, I'm not a good cost estimator, but I would just guess it would cost more than it did to do it the first time for sure. It would not be an easy proposition to do, it would not be an inexpensive proposition to do."
Benno ask ed whether complete removal and treatment, even though it might cost more, made more sense than a system that might fail, Palermo added: "I have no way of knowing that because I don't know what the cost estimates are to remove, you know, even what they propose to remove - I haven't seen those figures."
About the geotextile liner GE plans for the river, Mike Palermo declared: " ... here I don't see why it's really necessary because this excavation will be done in the dry - what will be left will be more or less the sandy material, fairly sandy material and so to me, you know, geotextile placed between that and the cap layer will, doesn't serve any function that I can think of ..."
Then Bryan Olson of the EPA stated: "the geotextile that separates the different layers of the cap, I think there are probably other ways to do that besides using that, that geotextiles ..."
Why, then, has the EPA continued to support GE's use of a rug for our river? Why can't we see the reasons for their decision? How does this serve the public interest? This cap, as Mike Palermo described, is being used as a containment option: to make sure that the toxic containment they are leaving in the river does not move and re-contaminate the river.
Palermo continued: "... in this particular half-mile reach, you know, the objective is going the next step - this cap has got to not only physically stabilize what sediments are left in place, it's also got to isolate those contaminants from moving up, you know, up through the cap and back into the river system. This cap design has that added level of concern in the design, another process that has to be looked at very closely." "It's easier to design the armoring layer to resist scouring or erosion than it is to design a cap to contain the contaminants under certain circumstances"
DO WE REALLY WANT A RUG FOR OUR RIVER?
These decisions are too important to be made by a computer modeling program. We need a pilot project to prove it will work. Last but not least, here are some of the agencies own guidelines for remediation projects:
According to the federal register of July 27, 1990, Corrective Action for Solid Waste Management Units at Hazardous Management Facilities; Proposed Rule (Subpart S), there are four standards used in evaluating Corrective Measure technologies. The four evaluation standards are:
- 1) overall protection of human health and the environment;
- 2) ability of the technology to attain media cleanup standards;
- 3) the ability of the technology to control the sources of releases; and,
- 4) the technology's compliance with standards for management of wastes.
If two or more technologies meet the evaluation standards then there are five evaluation decision factors which must be considered. The five evaluation decision factors are:
- 1) ability of the remedy to provide long-term reliability and effectiveness;
- 2) ability to reduce the toxicity, mobility, or volume of wastes;
- 3) short-term effectiveness;
- 4) ability to implement; and,
- 5) cost.
The evaluation standards and factors of Subpart S (with any subsequent modifications) together with those specified in Special Permit Condition II.M and in the Massachusetts Contingency Plan, shall be condition in the CMS. ...
10. In accordance with the Permit and the proposed Subpart S regulations, economic considerations shall not be the sole standard or criterion applied to any technology in the Corrective Measures evaluation process.
General Determinations
12. In general (especially in view of existing DEP and EPA policies and TSCA), GE needs to give full consideration to removal technologies coupled with ex-situ treatment and/or disposal. As required by the Permit, the PICM Proposal proposes to study a selected number of these technologies. After sediment is removed, potential next steps include, at a minimum: dewatering, treatment and disposal. In the CMS, GE shall better evaluate these next steps and evaluate them on a reach-by-reach basis. (pgs. 4-6) Vol. 5, MDEP Public Involvement Plan
It is our belief, that in their efforts to achieve a negotiated settlement, the agencies have unfortunately short-changed the larger public interest. While Pittsfield Mayor Gerald Doyle and Pittsfield City Council President Thomas Hickey did their best to advocate for the economic redevelopment of the GE site, and worked diligently to bring desperately needed jobs back to the city, the details of the settlement that are slowly being revealed demonstrate that there was a clear need for broader public participation at the negotiating table.