7 and achieve a reduction in PCB levels in fish that would allow consumption. EPA noted in its Record of Decision: “This selected remedy includes a combination of remedial activities that are tailored to the conditions at the Site, including removal of contaminated sediment using environmental dredging techniques, institutional controls, and MNA [monitored natural attenuation] of PCB contamination in the river until acceptable PCB concentrations in fish are attained.”5 EPA’s decisions on the scope of the project have been questioned by those who advocated for removal of a greater volume or all of the PCBs. The Agency evaluated — and rejected — a much larger dredging alternative in the Record of Decision. Over the last decade, EPA looked at multiple requests to expand dredging and This decision ... balances the public health and ecological needs to clean-up PCB contamination with the concerns expressed by ... the local communities. “ ” — NEW YORK STATE 2001 2000 2010 2020 2030 2040 2050 2060 Year 0.0 0.5 1.0 1.5 2.0 2.5 3.0 Tri+ PCB Concentration (mg/kg wet-weight) No Action MNA w/ Upstr. Source Control CAP - 3/10/Select REM - 3/10/Select (Chosen) REM - 0/0/3 0.4 mg/kg Threshold 0.2 mg/kg Threshold 0.05 mg/kg Threshold Upper Hudson River Species-Weighted Fish Fillet Average Tri+ PCB Concentration Data Source: Table 11-2 from the Hudson River PCBs Site Record of Decision. UHR average obtained by weighting RS1, RS2, and RS3 species-weighted results by factors of 0.154, 0.125, and 0.721, respectively. MM - \\NEREUS\E_Drive\Projects\GE_Hudson\Dredging_Analysis\Working\Model\Bioaccumulation\FISHRAND\PLOTS\FISHRAND_time_to_targets.pro Wed Jun 28 10:01:00 2017 What EPA’s Model Predicted in 2002: Data from EPA’s Record of Decision (February 2002, Table 11-2) show the projected timeframes for reductions of PCB levels in fish, based on a range of remedial options from No Action to a major dredging project. All options reduce PCB levels in fish. EPA selected the REM-3/10/Select (dark blue) over more extensive dredging (REM-0/0/3 light blue). The two dredging options show only a modest difference in the level of PCBs in fish over several years. Chart created by GE’s science consultant Anchor QEA from EPA data. FIGURE 1: COMPARING PCB LEVELS BY REMEDY 5 Hudson River PCBs Site New York Record of Decision, EPA, February 2002, Pg. v