GE Response to NY Times

The New York Times declared in an editorial on Feb. 8 that "some adjustments" will have to be made in the environmental dredging project under way in the Upper Hudson River to ensure that the project meets EPA's goals and is completed in the next five years.

We agree. And we were pleased to see that The Times virtually adopted the language GE used in the executive summary of its evaluation of the first phase of the project: "The analysis demonstrates that practical adjustments to the (engineering performance standards) are necessary to ensure that the project achieves the human health and environmental benefits projected by EPA."

While reaching the same conclusion, The Times editorial relied on inaccurate information about the dredging project that deserves to be corrected so that Times readers and everyone who cares about the Hudson has a clear understanding of the facts.

GE conducted the first phase of the largest and most logistically complex environmental dredging project in history last summer in the Upper Hudson River. The purpose was to remove river-bottom sediments that contain PCBs – chemicals that were once used in the manufacture of electrical products at two GE plants in Upstate New York and that were discharged to the river. After more than 30 years of public and scientific debate, the U.S. Environmental Protection Agency ordered the dredging project. GE has fully cooperated. We designed and conducted the project and paid for it – including paying our own costs and our own contractors and reimbursing the government for millions of dollars for its costs and its contractors. All of the work was performed under round-the-clock oversight by EPA and New York State. At times the project put more than 100 vessels in the river. More than 500 people were on the job.

The long debate about dredging focused on whether excavating the bottom of a fast-flowing river would spread PCB contamination and do more harm than good. The evaluation of the first phase of the work showed that, as feared, dredging released substantially more PCBs to the water, air, fish and sediment than EPA had predicted. If similarly high levels of PCBs are released by dredging in the next phase of the project, the environmental benefits EPA forecast will be eliminated.

Here are the facts:

Large amounts of sediment were removed from the river. Crews dredged nearly 290,000 cubic yards of sediment, containing approximately 35,000 pounds of PCBs. EPA's goal was to dredge 265,000 cubic yards.
The resuspension levels seen in the Upper Hudson during the first phase of dredging are consistent with what has been seen on other large dredging projects, such as the Grasse and Fox rivers projects. Prior to dredging, the level of PCBs in the water of the Upper Hudson averaged 30 to 50 parts per trillion. On ten occasions during the summer of 2009, the concentration of PCBs was 10 times that level, exceeding the federal drinking water standard of 500 parts per trillion.
Higher levels of PCBs in the water led to a 500 percent increase in the PCB levels in fish in the immediate area of the dredging and a 40-65 percent increase in PCB levels in fish 30 miles south of the dredging.
Dredging released PCBs into the air, and those levels exceeded the EPA's standard 105 times.

It's important to bear in mind that EPA's goals were to reduce the levels of PCBs in water and fish, reduce the amount of PCBs flowing downstream, and reduce the amount of PCBs that might become available to fish and other wildlife. Phase 1 achieved none of these goals. This is the reason GE has called for practical adjustments in the project.

While acknowledging the problems and challenges with the first phase of dredging, The Times editorial declares: "Most importantly, … the percentage of stirred-up PCBs that spilled over the last dam from the dredging hot spot into the cleaner lower river was actually lower than expected."

Not so.

The mass of PCBs that the first phase of dredging resuspended and that was conveyed over the last dam and into the Lower Hudson was nearly double EPA's maximum allowable limit. EPA set the limit at 117 kilograms (258 pounds). Dredging released 200 kilograms (440 pounds).

In recognition of the substantial resuspension of PCBs that occurred in Phase 1, EPA has now proposed tripling the amount of PCBs that can be resuspended into the Lower Hudson during Phase 2.

And it has also proposed doubling the rate of sediment removal in the second phase of dredging, even though it is the rate of removal and the velocity of the river that directly contribute to higher PCB resuspension.

As The Times correctly observed, the Hudson River dredging project is one of the most expensive and complex environmental cleanups in history – and one of the most closely watched. Getting the facts straight matters.