RCRA Facilities Investigation of GE Pittsfield PCB Contamination of the Housatonic River

U.S. Environmental Protection Agency, Region 1 and U.S. Army Corps of Engineers, under contract to Weston Solutions, Inc.

Description:

The Housatonic River flows from north of Pittsfield, MA to Long Island Sound and drains an area of approximately 1,950 square miles in Massachusetts, New York, and Connecticut. The Housatonic River, its sediment, and associated floodplain are contaminated with polychlorinated biphenyls (PCBs) and other hazardous substances released from the General Electric Company (GE) facility located in Pittsfield, MA. The site consists of the 254-acre GE manufacturing facility; the Housatonic River and associated riverbanks and floodplains from Pittsfield, MA, to Long Island Sound; former river oxbows that have been filled; neighboring commercial properties; Allendale School; Silver Lake; and other properties or areas that have become contaminated as a result of GE’s facility operations.

In September 1998, after years of scientific investigations and regulatory actions, a comprehensive agreement was reached between GE and various governmental entities, including the U.S. Environmental Protection Agency (EPA), the MassDEP, the U.S. Department of Justice (DOJ), the Connecticut Department of Environmental Protection (CTDEP), and the City of Pittsfield. The agreement provides for the investigation and cleanup of the Housatonic River and associated areas with a focus on CERCLA-related compliance.

On 1 January 2019, Bluestone acquired Avatar Environmental, LLC. Bluestone (Avatar) was involved in the RCRA/CERCLA cleanup and site investigative process from the beginning on behalf of CENAE and EPA Region 1 in a wide variety of activities including:

• Project planning and scoping
• Technical support
• Engineering Evaluation/Cost Analysis (EE/CA) development support
• Site investigations
• Regulatory agency negotiations
• Human Health Risk Assessment (HHRA)
• Ecological Risk Assessment (ERA)
• Community and Public Involvement
• Peer Review Support

Bluestone was instrumental in the overall planning process and the implementation of the effort that collected, processed, and analyzed over 10,000 surface water, sediment, soil, and biological tissue samples. The Team coordinated and provided oversight for numerous field and laboratory studies conducted by subcontractors, research institutions and other government agencies.

Bluestone risk assessors and toxicologists evaluated PCB and dioxin-like PCB congener risk resulting from contamination along a 130-mile stretch of the Housatonic River south of Pittsfield, MA to Long Island Sound. Bluestone provided documentation that allowed the various federal and state agencies to eliminate 180 properties from further evaluation, saving significant time and money.

Prior to performing more than 200 floodplain property risk assessments, Bluestone developed a computerized risk assessment program which reduced the time and cost for completing these assessments by roughly 30%.

Bluestone developed an evaluation of potential risks from turtle and frog consumption that allowed the regulatory agencies to forego an expensive biota sampling effort saving the project over $50K in sampling and analysis costs.

Bluestone employed innovative approaches such as Monte Carlo analysis, Probability Bounds analysis, and geostatistical averaging techniques that precluded overly conservative evaluations.

Since 2014 Bluestone has been performing work at the site under a $25M, 5-year professional services contract. Activities performed under this contract include:

• The site involves multiple stakeholders, including EPA Region 1, CENAE, MassDEP, GE, USFWS, City of Pittsfield, multiple public interest groups and the general public. While the consent decree between EPA and GE is a CERCLA consent decree, the investigations and reporting follow the RCRA procedures and guidance and so both regulatory programs are relevant.
• EPA Region 1 issued a Statement of Basis for the Rest of River (RoR) (~125 miles of river starting at the confluence of the east and west branches) in June 2014. Bluestone supported EPA by assisting in preparing responses to comments received on the proposed remedy.
• Organized 800+ comments to the Statement of Basis (Proposed Plan) and Draft Modification to the Reissued RCRA Permit.
• Negotiated and awarded 5+ subcontracts for technical expert input to responses.
• Following issuance of the Final RCRA Permit modification GE appealed the decision to the EPA Environmental Appeals Board (EAB). Bluestone assisted EPA in preparing briefs for the EAB, responding to questions from the EAB and making presentations to the EAB in Washington, DC.
• Bluestone provides technical support for uncontested portions of the Final RCRA Permit modification. The team of technical experts have reviewed and provided comments for GE’s Baseline Monitoring Plan and Floodplain Pre-Design Investigation Work Plan.
• Bluestone provided technical review, input and field oversight to a GE proposal for alternative risk-based, site-specific chlorobenzene groundwater standards to replace the MassDEP MCP Method 1 GW-3 standard for GMA 1 and GMA 3 wells.
• Bluestone reviewed the construction work plans and provided oversight of GE remedial actions to clean up Unkamet Brook, a major tributary to the Housatonic River. The work included a temporary brook diversion system, sediment/soil removal and restoration activities, offsite disposal, surface water sampling, turbidity, PCB and particulate air monitoring.
• Bluestone also reviewed the construction work plans and provided oversight of GE remedial actions to clean up residential floodplain properties contaminated with PCBs from 6 areas up to 10 miles downriver from the former GE facility. Bluestone provided oversight of all the work including building temporary roads, sediment/soil removal, backfilling and restoration activities, offsite disposal (hazardous, non-hazardous and TSCA waste), and construction monitoring.
• Oversight of post removal site control activities at 18 completed removal action areas and the Upper ½-Mile Reach removal including Environmental Restriction Easements and Conditional Solution inspections.
• Oversight of corrective actions includes re-vegetation efforts, invasive species control efforts, soil/riprap erosion repairs, and cap material placement at Silver Lake.
• Some of the areas being monitored are natural resource restoration/enhancement areas, which require coordination with the Trustees (MassDEP and USFWS).
• Bluestone collects routine surface water split samples from 2 locations within the river for PCB aroclor and PCB congener analysis. Detailed evaluation of congener split sample results and comparisons between aroclor and congener data is performed annually.
• Bluestone reviewed the Silver Lake Final Completion Report prepared by GE documenting the sediment removal and sediment capping performed at Silver Lake.
• Bluestone oversees all aspects of GE’s O&M activities including inspections, monitoring and maintenance in and out of the river to ensure all performance goals are met. The items that are being inspected and maintained include engineered barriers, re-vegetation (trees, shrubs, presence of invasive species), integrity of soil and riprap, articulated concrete blocks, ancillary items (retaining walls, guardrails and fencing), and Silver Lake Cap monitoring.
• Bluestone manages a 1GB environmental database with 1M+ analytical results from 75,000 locations that links directly to a GIS for mapping and data analysis. This data management system includes all data collected over the past 15 years. New data from GE as well as split sample results are continually added to the system. Bluestone provides oversight of GE groundwater sampling, DNAPL recovery, and reviews semi-annual groundwater management area reports.