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.

Dredging was conducted in only 10 of 18 areas targeted for dredging. Dredging could not be conducted in all of the areas originally targeted because EPA required removal of more than 120,000 additional cubic yards of sediment than forecast in the 10 areas.

EPA established the Productivity Standard in 2004 to ensure that the dredging project was completed in six years – one year for Phase 1, and five years for Phase 2.  A longer dredging project would extend resuspension of PCBs in water and result in elevated PCB levels in fish for a longer period of time.

The Productivity Standard required removal of 89,000 cubic yards of sediment in a single month during Phase 1. The standard was not met. In the best month for productivity in Phase 1, 77,300 cubic yards of sediment was removed.

Productivity was hampered by three factors: resuspension of PCBs, which resulted in dredging slowdowns and adjustments; exceedances in the air quality standard, which also required dredging process modifications; and the multiple, unproductive re-dredging attempts necessary to meet the Residual Standard.

For Phase 2, EPA has assumed that twice as much sediment can be dredged each month than was removed during the best month in Phase 1. EPA is considering requiring removal of more than 100,000 cubic yards per month. GE’s analysis shows it is possible to dredge 75,000 to 100,000 cubic yards of sediment each month, but that resuspension of PCBs will prevent achieving this rate.

EPA’s productivity requirement for Phase 2 is not practical. It ignores the experience of Phase 1 and the demonstrated result that greater removal means greater resuspension and higher PCB levels in water, air, sediment and fish.

GE recommends that the five-year duration of Phase 2 be retained and that a practical Productivity Standard be established in accord with the other performance standards to protect the environmental benefits that EPA forecast.