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Independent Panel Reviewing First Phase of Hudson Dredging

GE conducted the first phase of the Upper Hudson River Dredging Project between May 15 and December 4, 2009. Dredging was conducted 24 hours a day, six days a week and was overseen by the U.S. Environmental Protection Agency, New York State and the U.S. Army Corps of Engineers  (click here to learn more).

The agreement between EPA and GE under which the project is being conducted required that the results of Phase 1 be evaluated by an independent peer review panel. Both EPA and GE prepared evaluations of the project for submission to the peer review, which met for the first time on Feb 17-18 to review the information.

GE's evaluation is based on its analysis of more than 18,000 air, water and sediment samples that were collected during and after dredging. In its report and presentation to the peer reviewers, GE's goal is to improve the second phase of the dredging project so that it achieves the environmental goals EPA has forecast.

In 2004, EPA established engineering performance standards to govern the project. It required that dredging meet these standards consistently and simultaneously. Despite the use of the best available dredging technology, daily oversight by regulatory agencies, and multiple modifications in the dredging process, the standards could not be met consistently and simultaneously because they are in conflict with one another. For example, attempts to achieve the Productivity Standard led to exceedances in the Resuspension Standard. Attempts to limit resuspension or to meet the Residual Standard inhibited productivity.

The first phase of dredging released more PCBs to the water, air and fish in the Upper Hudson and more PCBs to the Lower Hudson than EPA predicted. GE believes that practical adjustments to the standards should be made to help ensure the rest of the project meets EPA's goals to reduce PCB levels in fish, water and sediments, to reduce PCB transport downstream and to reduce PCB levels in surface sediments where they are bioavailable to fish and wildlife.

GE's recommendations include: setting a not-to-exceed maximum limit on the mass of PCBs the dredging project releases downstream; keeping the federal drinking water standard as a performance standard; maintaining EPA's five-year schedule for the second phase of the project; and, adjusting the productivity and residual standards to achieve EPA's goals of reducing the amount of PCBs in fish, water, sediment and transported downstream.

The Resuspension Standard

EPA established two resuspension standards to ensure that dredging did not cause exceedances of the drinking water standard and did not release more PCBs into the river than would have happened over time without dredging. Read more ...

The Productivity Standard

For the first phase of dredging, EPA established a target for removal of 265,000 cubic yards of sediment. In fact, 286,000 cubic yards of sediment containing 16,300 kg (35,000 pounds) of PCBs was removed.  Dredging took place 24 hours a day, six days a week. At times, more than 100 vessels were at work on the river. More than 500 people were employed. Read more ...

The Residual Standard

EPA established the Residual Standard — the amount of PCBs left on the surface sediments after dredging — to reduce the amount of PCBs that are or may become bioavailable. EPA's target average for five-acre dredge areas was approximately 0.25 ppm, about one-quarter of a part per million. Sampling was required after each dredging pass to measure the mass of PCBs left behind. Read more ...

Conclusions

Phase 1 of the Hudson River Dredging Project was designed as a test to determine whether the engineering performance standards established by EPA could be met simultaneously and consistently. The experience showed that the standards are in conflict with each other and cannot be met.

GE recommends that practical adjustments be made in the standards to help ensure the project achieves the environmental benefits EPA forecast. The goals of the dredging project, as established by EPA, are to reduce PCB levels in water and fish, to reduce downstream transport of PCBs, and to reduce PCBs that are bioavailable to fish and wildlife.

The Phase 1 data and experience demonstrated that resuspension of PCBs threatens achievement of these goals. It also demonstrated that resuspension is directly linked to the mass of PCBs removed and that resuspension controls generally were not effective.

To achieve the goals EPA established for this project, GE believes that EPA must impose a not-to-exceed maximum limit on the mass of PCBs that dredging releases downstream over the five years of Phase 2. To comply with the maximum limit, GE recommends that EPA modify the Resuspension and Residuals standards.