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FfAL o-
RCRA RECORDS CENTER FACU ITY d ID NO A vFILE LOG OTHER
REPORT BLASLANO A BOUCK ENGINEERS PO
HOUSATONIC RIVER STUDY 90-Day Interim Report
REMEDIAL ALTERNATIVES EVALUATION
- Flow and Velocity Control - River Channelization - In-situ Impoundment
General Electric Company Pittsfield Massachusetts
November 1984
Draft 11 1 5 8 4
HOUSATONIC RIVER STUDY
90-DAY INTERIM REPORT
REMEDIAL ALTERNATIVES EVALUATION
- FLOW AND VELOCITY CONTROL
- RIVER CHANNELIZATION
- IN-SITU IMPOUNDMENT
GENERAL ELECTRIC COMPANY
PITTSFIELD MASSACHUSETTS
November 1984
This Report was prepared for the General Electric Company by
Blasland amp Bouck Engineers PC 5793 Widewaters Parkway Cox 66 Syracuse New York 13214
Erseco Inc 161 Forbes Road Suite 204 Braintree Massachusetts 02184
OBrien amp Gere Engineers Inc Raritan Plaza III Fieldcrest Avenue Edison New Jersey 08837
Dravo Van Houten Consulting Engineers Eleven Penn Plaza New York New York 10001
DRAFT 1 1 1 5 8 4
TABLE OF CONTENTS
Acknowledgement Page No
Section 1 Executive Summary 1
Section 2 Introduction 6
21 General 6
22 Purpose and Scope of This Work Effort 7
23 PCB-laden Sediments - Location and Description 7
Section 3 Overview of Applicable Regulations 9
31 Introduction 9
32 Regulatory Interests 9
33 Application of the National Contingency Plan 10
34 Previous Studies 11
Section 4 Flow and Velocity Control Alternative 13
41 General 13
42 Description of Alternative 13
43 Pre-Construction and Construction Activities 15
44 Scheduling 16
45 Major Engineering Design Considerations 17
46 Potential Environmental Impacts 18
Section 5 River Channelization Alternative 19
51 General 19
52 Description of Alternative 19
53 Pre-Construction and Construction Activities 20
54 Scheduling 21
55 Major Engineering Design Considerations 22
56 Major Potential Environmental Impacts 22
DRAFT 1 1 1 5 8 4
Page No
Section 6 In-situ Impoundment Alternative 25
61 General 25
62 Description of Alternative 25
63 Pre-Construction and Construction Activities 27
64 Scheduling 28
65 Major Engineering Design Considerations 28
66 Major Potential Environmental Impacts 29
Section 7 Application of Regulations 32
71 Introduction 32
72 Federal Regulations 33
73 State Regulations 35
74 Local RegulationsRequirements 39
75 Summary 40
Section 8 Summary and Recommendations 42
81 Summary and Recommendations 42
References
ACKNOWLEDGEMENT
Portions of this report were prepared by other consultants
Specifically Erseco Inc prepared Sections 3 and 7 OBrien 6 Cere
Engineers Inc prepared Sections 4 and 6 and Dravo Van Houten Consulting
Engineers prepared Section 5 In addition Erseco Inc assisted Blasland amp
Bouck Engineers PC by providing general consultation and review
Executive Summary BLASLANO ft BOUCK ENGINEERS PO
SECTION 1 - EXECUTIVE SUMMARY
This 90-Day Interim Report was prepared to provide the framework for
evaluating three types of remedial actions in controlling PCB-laden sediments
(greater than 50 ppm) in the Housatonic River Specifically the three types
of remedial actions are
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
This Interim Report is the second in a series of successive reports
prepared to address potential remedial alternatives for the Housatonic River
A previous report entitled the 45-Day Interim Report dated October 1984
(Reference 1) addressed the remedial alternative of dredging the PCB-laden
sediments from the river and disposing of these sediments in a local disposal
facility in accordance with Federal and State regulations
This 90-Day Interim Report provides a preliminary description of each of
the alternatives listed above along with establishing the engineering design
and construction considerations potential major environmental impacts and
estimated schedules for project completion A summary of the findings of this
report follows
FLOW AND VELOCITY CONTROL
The Flow and Velocity Control Alternative consists of modifying the
existing Schweitzer Dam below Woods Pond to further increase the ability of
- 1 shy
Woods Pond to act as a reliable and efficient sediment trap for PCB-laden
sediments (greater than 50 ppm) This may be accomplished by implementing
the following actions
1 Elimination of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
The purpose of these activities is to induce increased sediment deposition
in Woods Pond and inhibit resuspension and transport of the sediments to the
downstream river This is accomplished by reducing the water flow velocities
in Woods Pond and in the approach channel to the Schweitzer Dam
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Conduct safety and stability analyses of the dam and abutments
2 Structural design of selected flow and velocity control option
3 Development and design of a future reservoir drawdown system to
replace existing raceway and
H Development of a method to reduce the potential for sediment
movement during construction activities
It is estimated that the overall implementation schedule for any of the
flow and velocity control alternatives would be two years
RIVER CHANNELIZATION
The River Channelization Alternative consists of re-routing portions of
the Housatonic River by means of a new channel such that the river flow
does not contact PCB-laden sediments (greater than 50 ppm) This new river
channel is intended to connect river segments with known non-PCB-laden
sediments while bypassing those segments with known PCB-laden sediments
(greater than 50 ppm)
The major engineering design and environmental considerations associated
with this alternative and summarized below
1 Development of a technique(s) to drain those areas being bypassed
2 Determination of the acceptability of excavated soils as embankment
materials
3 Determination of location of spoil or disposal areas for excess
excavated materials
4 Evaluation of potential flood storage volume impacts
5 Evaluation of potential groundwater and surface water impacts
6 Evaluation of environmental impacts upon the wetland areas
associated with Woods Pond and the backwater areas
7 Evaluation of construction activities upon local transportation
routes
8 Evaluation of impact upon recreational activities within the
Housatonic River Wildlife Management Area and
9 Evaluation of the impacts of construction activities upon the local
public
- 3 shy
It is estimated that the overall implementation schedule for the river
channelization alternative would be four years
IN-SITU IMPOUNDMENT
The In-situ Impoundment Alternative entails the in-place stabilization of
PCB-laden sediments (greater than 50 ppm) by either physical isolation
(armoring) or by the addition of binding materials (chemical stabilization) to
minimize sediment transport The armoring option consists of covering
PCB-laden sediments with granular materials such as sand and gravel and the
chemical stabilization option consists of using binding materials such as fly
ash or cement to combine with the sediments to form a hardened soil mass
thus reducing the potential for sediment transport
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
5 Identification of the strength required and methods necessary to
obtain a stable base
6 Development of an inspection program to evaluate and maintain the
effectiveness of this alternative
7 Development of a method to reduce the potential for sediment
movement during construction activities
8 Evaluation of environmental impacts upon the wetland and backwater
areas during installation of the armoring or stabilization materials
9 Evaluation of construction activities upon local transportation
routes
10 Evaluation of potential flood storage volume impacts and
11 Evaluation of impacts of construction activities upon the local
public
It is estimated that the overall implementation schedule for either in-situ
impoundment alternative would be four to five years
For all remedial actions evaluated in this Interim Report there exist a
number of Federal State and local regulations which govern the various
remedial activities The appropriate regulations and review authorities are
identified for each alternative in this Report
The next report prepared the 135-Day Interim Report will present the
further evaluation of all the remedial alternatives presented within the 45shy
and 90-Day Interim Reports and will include recommendations for those
alternatives to be evaluated in greater detail withjn the final 210-Day Report
- 5 shy
Introduction BLASLAND amp BOUCK ENGINEERS PC
SECTION 2 - INTRODUCTION
21 General
This 90-Day Interim Report will present a preliminary evaluation of three
remedial action alternatives proposed to control PCB-laden sediments (greater
than 50 ppm) in the Housatonic River These three remedial action
alternatives are as follows
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
A previous report entitled the US-Day Interim Report (Reference 1)
dated October 1984 presented an evaluation of the sediment removal and local
disposal alternative and also provided detailed background information as to
the development of the four proposed alternatives being evaluated (the three
listed above and sediment removal)
The 135-Day Interim Report will further evaluate potentially adverse
environmental impacts and present additional engineering assessments of those
alternatives presented in the 45-Day and 90-Day Interim Reports The
135-Day Interim Report will also present recommendations for screening out
those alternatives which do not warrant any further detailed evaluation
because of their engineering effectiveness adverse environmental impacts
restrictive regulatory requirements or public reluctance
- 6 shy
22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
- 7 shy
Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
- 8 shy
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
Draft 11 1 5 8 4
HOUSATONIC RIVER STUDY
90-DAY INTERIM REPORT
REMEDIAL ALTERNATIVES EVALUATION
- FLOW AND VELOCITY CONTROL
- RIVER CHANNELIZATION
- IN-SITU IMPOUNDMENT
GENERAL ELECTRIC COMPANY
PITTSFIELD MASSACHUSETTS
November 1984
This Report was prepared for the General Electric Company by
Blasland amp Bouck Engineers PC 5793 Widewaters Parkway Cox 66 Syracuse New York 13214
Erseco Inc 161 Forbes Road Suite 204 Braintree Massachusetts 02184
OBrien amp Gere Engineers Inc Raritan Plaza III Fieldcrest Avenue Edison New Jersey 08837
Dravo Van Houten Consulting Engineers Eleven Penn Plaza New York New York 10001
DRAFT 1 1 1 5 8 4
TABLE OF CONTENTS
Acknowledgement Page No
Section 1 Executive Summary 1
Section 2 Introduction 6
21 General 6
22 Purpose and Scope of This Work Effort 7
23 PCB-laden Sediments - Location and Description 7
Section 3 Overview of Applicable Regulations 9
31 Introduction 9
32 Regulatory Interests 9
33 Application of the National Contingency Plan 10
34 Previous Studies 11
Section 4 Flow and Velocity Control Alternative 13
41 General 13
42 Description of Alternative 13
43 Pre-Construction and Construction Activities 15
44 Scheduling 16
45 Major Engineering Design Considerations 17
46 Potential Environmental Impacts 18
Section 5 River Channelization Alternative 19
51 General 19
52 Description of Alternative 19
53 Pre-Construction and Construction Activities 20
54 Scheduling 21
55 Major Engineering Design Considerations 22
56 Major Potential Environmental Impacts 22
DRAFT 1 1 1 5 8 4
Page No
Section 6 In-situ Impoundment Alternative 25
61 General 25
62 Description of Alternative 25
63 Pre-Construction and Construction Activities 27
64 Scheduling 28
65 Major Engineering Design Considerations 28
66 Major Potential Environmental Impacts 29
Section 7 Application of Regulations 32
71 Introduction 32
72 Federal Regulations 33
73 State Regulations 35
74 Local RegulationsRequirements 39
75 Summary 40
Section 8 Summary and Recommendations 42
81 Summary and Recommendations 42
References
ACKNOWLEDGEMENT
Portions of this report were prepared by other consultants
Specifically Erseco Inc prepared Sections 3 and 7 OBrien 6 Cere
Engineers Inc prepared Sections 4 and 6 and Dravo Van Houten Consulting
Engineers prepared Section 5 In addition Erseco Inc assisted Blasland amp
Bouck Engineers PC by providing general consultation and review
Executive Summary BLASLANO ft BOUCK ENGINEERS PO
SECTION 1 - EXECUTIVE SUMMARY
This 90-Day Interim Report was prepared to provide the framework for
evaluating three types of remedial actions in controlling PCB-laden sediments
(greater than 50 ppm) in the Housatonic River Specifically the three types
of remedial actions are
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
This Interim Report is the second in a series of successive reports
prepared to address potential remedial alternatives for the Housatonic River
A previous report entitled the 45-Day Interim Report dated October 1984
(Reference 1) addressed the remedial alternative of dredging the PCB-laden
sediments from the river and disposing of these sediments in a local disposal
facility in accordance with Federal and State regulations
This 90-Day Interim Report provides a preliminary description of each of
the alternatives listed above along with establishing the engineering design
and construction considerations potential major environmental impacts and
estimated schedules for project completion A summary of the findings of this
report follows
FLOW AND VELOCITY CONTROL
The Flow and Velocity Control Alternative consists of modifying the
existing Schweitzer Dam below Woods Pond to further increase the ability of
- 1 shy
Woods Pond to act as a reliable and efficient sediment trap for PCB-laden
sediments (greater than 50 ppm) This may be accomplished by implementing
the following actions
1 Elimination of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
The purpose of these activities is to induce increased sediment deposition
in Woods Pond and inhibit resuspension and transport of the sediments to the
downstream river This is accomplished by reducing the water flow velocities
in Woods Pond and in the approach channel to the Schweitzer Dam
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Conduct safety and stability analyses of the dam and abutments
2 Structural design of selected flow and velocity control option
3 Development and design of a future reservoir drawdown system to
replace existing raceway and
H Development of a method to reduce the potential for sediment
movement during construction activities
It is estimated that the overall implementation schedule for any of the
flow and velocity control alternatives would be two years
RIVER CHANNELIZATION
The River Channelization Alternative consists of re-routing portions of
the Housatonic River by means of a new channel such that the river flow
does not contact PCB-laden sediments (greater than 50 ppm) This new river
channel is intended to connect river segments with known non-PCB-laden
sediments while bypassing those segments with known PCB-laden sediments
(greater than 50 ppm)
The major engineering design and environmental considerations associated
with this alternative and summarized below
1 Development of a technique(s) to drain those areas being bypassed
2 Determination of the acceptability of excavated soils as embankment
materials
3 Determination of location of spoil or disposal areas for excess
excavated materials
4 Evaluation of potential flood storage volume impacts
5 Evaluation of potential groundwater and surface water impacts
6 Evaluation of environmental impacts upon the wetland areas
associated with Woods Pond and the backwater areas
7 Evaluation of construction activities upon local transportation
routes
8 Evaluation of impact upon recreational activities within the
Housatonic River Wildlife Management Area and
9 Evaluation of the impacts of construction activities upon the local
public
- 3 shy
It is estimated that the overall implementation schedule for the river
channelization alternative would be four years
IN-SITU IMPOUNDMENT
The In-situ Impoundment Alternative entails the in-place stabilization of
PCB-laden sediments (greater than 50 ppm) by either physical isolation
(armoring) or by the addition of binding materials (chemical stabilization) to
minimize sediment transport The armoring option consists of covering
PCB-laden sediments with granular materials such as sand and gravel and the
chemical stabilization option consists of using binding materials such as fly
ash or cement to combine with the sediments to form a hardened soil mass
thus reducing the potential for sediment transport
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
5 Identification of the strength required and methods necessary to
obtain a stable base
6 Development of an inspection program to evaluate and maintain the
effectiveness of this alternative
7 Development of a method to reduce the potential for sediment
movement during construction activities
8 Evaluation of environmental impacts upon the wetland and backwater
areas during installation of the armoring or stabilization materials
9 Evaluation of construction activities upon local transportation
routes
10 Evaluation of potential flood storage volume impacts and
11 Evaluation of impacts of construction activities upon the local
public
It is estimated that the overall implementation schedule for either in-situ
impoundment alternative would be four to five years
For all remedial actions evaluated in this Interim Report there exist a
number of Federal State and local regulations which govern the various
remedial activities The appropriate regulations and review authorities are
identified for each alternative in this Report
The next report prepared the 135-Day Interim Report will present the
further evaluation of all the remedial alternatives presented within the 45shy
and 90-Day Interim Reports and will include recommendations for those
alternatives to be evaluated in greater detail withjn the final 210-Day Report
- 5 shy
Introduction BLASLAND amp BOUCK ENGINEERS PC
SECTION 2 - INTRODUCTION
21 General
This 90-Day Interim Report will present a preliminary evaluation of three
remedial action alternatives proposed to control PCB-laden sediments (greater
than 50 ppm) in the Housatonic River These three remedial action
alternatives are as follows
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
A previous report entitled the US-Day Interim Report (Reference 1)
dated October 1984 presented an evaluation of the sediment removal and local
disposal alternative and also provided detailed background information as to
the development of the four proposed alternatives being evaluated (the three
listed above and sediment removal)
The 135-Day Interim Report will further evaluate potentially adverse
environmental impacts and present additional engineering assessments of those
alternatives presented in the 45-Day and 90-Day Interim Reports The
135-Day Interim Report will also present recommendations for screening out
those alternatives which do not warrant any further detailed evaluation
because of their engineering effectiveness adverse environmental impacts
restrictive regulatory requirements or public reluctance
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22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
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Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
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Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
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There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
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34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
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The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
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Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
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FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
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end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
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FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
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1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
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46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
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River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
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SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
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FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
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3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
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In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
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FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
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FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
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FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
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1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
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Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
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72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
This Report was prepared for the General Electric Company by
Blasland amp Bouck Engineers PC 5793 Widewaters Parkway Cox 66 Syracuse New York 13214
Erseco Inc 161 Forbes Road Suite 204 Braintree Massachusetts 02184
OBrien amp Gere Engineers Inc Raritan Plaza III Fieldcrest Avenue Edison New Jersey 08837
Dravo Van Houten Consulting Engineers Eleven Penn Plaza New York New York 10001
DRAFT 1 1 1 5 8 4
TABLE OF CONTENTS
Acknowledgement Page No
Section 1 Executive Summary 1
Section 2 Introduction 6
21 General 6
22 Purpose and Scope of This Work Effort 7
23 PCB-laden Sediments - Location and Description 7
Section 3 Overview of Applicable Regulations 9
31 Introduction 9
32 Regulatory Interests 9
33 Application of the National Contingency Plan 10
34 Previous Studies 11
Section 4 Flow and Velocity Control Alternative 13
41 General 13
42 Description of Alternative 13
43 Pre-Construction and Construction Activities 15
44 Scheduling 16
45 Major Engineering Design Considerations 17
46 Potential Environmental Impacts 18
Section 5 River Channelization Alternative 19
51 General 19
52 Description of Alternative 19
53 Pre-Construction and Construction Activities 20
54 Scheduling 21
55 Major Engineering Design Considerations 22
56 Major Potential Environmental Impacts 22
DRAFT 1 1 1 5 8 4
Page No
Section 6 In-situ Impoundment Alternative 25
61 General 25
62 Description of Alternative 25
63 Pre-Construction and Construction Activities 27
64 Scheduling 28
65 Major Engineering Design Considerations 28
66 Major Potential Environmental Impacts 29
Section 7 Application of Regulations 32
71 Introduction 32
72 Federal Regulations 33
73 State Regulations 35
74 Local RegulationsRequirements 39
75 Summary 40
Section 8 Summary and Recommendations 42
81 Summary and Recommendations 42
References
ACKNOWLEDGEMENT
Portions of this report were prepared by other consultants
Specifically Erseco Inc prepared Sections 3 and 7 OBrien 6 Cere
Engineers Inc prepared Sections 4 and 6 and Dravo Van Houten Consulting
Engineers prepared Section 5 In addition Erseco Inc assisted Blasland amp
Bouck Engineers PC by providing general consultation and review
Executive Summary BLASLANO ft BOUCK ENGINEERS PO
SECTION 1 - EXECUTIVE SUMMARY
This 90-Day Interim Report was prepared to provide the framework for
evaluating three types of remedial actions in controlling PCB-laden sediments
(greater than 50 ppm) in the Housatonic River Specifically the three types
of remedial actions are
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
This Interim Report is the second in a series of successive reports
prepared to address potential remedial alternatives for the Housatonic River
A previous report entitled the 45-Day Interim Report dated October 1984
(Reference 1) addressed the remedial alternative of dredging the PCB-laden
sediments from the river and disposing of these sediments in a local disposal
facility in accordance with Federal and State regulations
This 90-Day Interim Report provides a preliminary description of each of
the alternatives listed above along with establishing the engineering design
and construction considerations potential major environmental impacts and
estimated schedules for project completion A summary of the findings of this
report follows
FLOW AND VELOCITY CONTROL
The Flow and Velocity Control Alternative consists of modifying the
existing Schweitzer Dam below Woods Pond to further increase the ability of
- 1 shy
Woods Pond to act as a reliable and efficient sediment trap for PCB-laden
sediments (greater than 50 ppm) This may be accomplished by implementing
the following actions
1 Elimination of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
The purpose of these activities is to induce increased sediment deposition
in Woods Pond and inhibit resuspension and transport of the sediments to the
downstream river This is accomplished by reducing the water flow velocities
in Woods Pond and in the approach channel to the Schweitzer Dam
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Conduct safety and stability analyses of the dam and abutments
2 Structural design of selected flow and velocity control option
3 Development and design of a future reservoir drawdown system to
replace existing raceway and
H Development of a method to reduce the potential for sediment
movement during construction activities
It is estimated that the overall implementation schedule for any of the
flow and velocity control alternatives would be two years
RIVER CHANNELIZATION
The River Channelization Alternative consists of re-routing portions of
the Housatonic River by means of a new channel such that the river flow
does not contact PCB-laden sediments (greater than 50 ppm) This new river
channel is intended to connect river segments with known non-PCB-laden
sediments while bypassing those segments with known PCB-laden sediments
(greater than 50 ppm)
The major engineering design and environmental considerations associated
with this alternative and summarized below
1 Development of a technique(s) to drain those areas being bypassed
2 Determination of the acceptability of excavated soils as embankment
materials
3 Determination of location of spoil or disposal areas for excess
excavated materials
4 Evaluation of potential flood storage volume impacts
5 Evaluation of potential groundwater and surface water impacts
6 Evaluation of environmental impacts upon the wetland areas
associated with Woods Pond and the backwater areas
7 Evaluation of construction activities upon local transportation
routes
8 Evaluation of impact upon recreational activities within the
Housatonic River Wildlife Management Area and
9 Evaluation of the impacts of construction activities upon the local
public
- 3 shy
It is estimated that the overall implementation schedule for the river
channelization alternative would be four years
IN-SITU IMPOUNDMENT
The In-situ Impoundment Alternative entails the in-place stabilization of
PCB-laden sediments (greater than 50 ppm) by either physical isolation
(armoring) or by the addition of binding materials (chemical stabilization) to
minimize sediment transport The armoring option consists of covering
PCB-laden sediments with granular materials such as sand and gravel and the
chemical stabilization option consists of using binding materials such as fly
ash or cement to combine with the sediments to form a hardened soil mass
thus reducing the potential for sediment transport
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
5 Identification of the strength required and methods necessary to
obtain a stable base
6 Development of an inspection program to evaluate and maintain the
effectiveness of this alternative
7 Development of a method to reduce the potential for sediment
movement during construction activities
8 Evaluation of environmental impacts upon the wetland and backwater
areas during installation of the armoring or stabilization materials
9 Evaluation of construction activities upon local transportation
routes
10 Evaluation of potential flood storage volume impacts and
11 Evaluation of impacts of construction activities upon the local
public
It is estimated that the overall implementation schedule for either in-situ
impoundment alternative would be four to five years
For all remedial actions evaluated in this Interim Report there exist a
number of Federal State and local regulations which govern the various
remedial activities The appropriate regulations and review authorities are
identified for each alternative in this Report
The next report prepared the 135-Day Interim Report will present the
further evaluation of all the remedial alternatives presented within the 45shy
and 90-Day Interim Reports and will include recommendations for those
alternatives to be evaluated in greater detail withjn the final 210-Day Report
- 5 shy
Introduction BLASLAND amp BOUCK ENGINEERS PC
SECTION 2 - INTRODUCTION
21 General
This 90-Day Interim Report will present a preliminary evaluation of three
remedial action alternatives proposed to control PCB-laden sediments (greater
than 50 ppm) in the Housatonic River These three remedial action
alternatives are as follows
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
A previous report entitled the US-Day Interim Report (Reference 1)
dated October 1984 presented an evaluation of the sediment removal and local
disposal alternative and also provided detailed background information as to
the development of the four proposed alternatives being evaluated (the three
listed above and sediment removal)
The 135-Day Interim Report will further evaluate potentially adverse
environmental impacts and present additional engineering assessments of those
alternatives presented in the 45-Day and 90-Day Interim Reports The
135-Day Interim Report will also present recommendations for screening out
those alternatives which do not warrant any further detailed evaluation
because of their engineering effectiveness adverse environmental impacts
restrictive regulatory requirements or public reluctance
- 6 shy
22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
- 7 shy
Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
- 8 shy
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
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FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
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46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
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River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
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FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
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3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
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In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
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FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
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FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
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FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
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Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
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72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
DRAFT 1 1 1 5 8 4
TABLE OF CONTENTS
Acknowledgement Page No
Section 1 Executive Summary 1
Section 2 Introduction 6
21 General 6
22 Purpose and Scope of This Work Effort 7
23 PCB-laden Sediments - Location and Description 7
Section 3 Overview of Applicable Regulations 9
31 Introduction 9
32 Regulatory Interests 9
33 Application of the National Contingency Plan 10
34 Previous Studies 11
Section 4 Flow and Velocity Control Alternative 13
41 General 13
42 Description of Alternative 13
43 Pre-Construction and Construction Activities 15
44 Scheduling 16
45 Major Engineering Design Considerations 17
46 Potential Environmental Impacts 18
Section 5 River Channelization Alternative 19
51 General 19
52 Description of Alternative 19
53 Pre-Construction and Construction Activities 20
54 Scheduling 21
55 Major Engineering Design Considerations 22
56 Major Potential Environmental Impacts 22
DRAFT 1 1 1 5 8 4
Page No
Section 6 In-situ Impoundment Alternative 25
61 General 25
62 Description of Alternative 25
63 Pre-Construction and Construction Activities 27
64 Scheduling 28
65 Major Engineering Design Considerations 28
66 Major Potential Environmental Impacts 29
Section 7 Application of Regulations 32
71 Introduction 32
72 Federal Regulations 33
73 State Regulations 35
74 Local RegulationsRequirements 39
75 Summary 40
Section 8 Summary and Recommendations 42
81 Summary and Recommendations 42
References
ACKNOWLEDGEMENT
Portions of this report were prepared by other consultants
Specifically Erseco Inc prepared Sections 3 and 7 OBrien 6 Cere
Engineers Inc prepared Sections 4 and 6 and Dravo Van Houten Consulting
Engineers prepared Section 5 In addition Erseco Inc assisted Blasland amp
Bouck Engineers PC by providing general consultation and review
Executive Summary BLASLANO ft BOUCK ENGINEERS PO
SECTION 1 - EXECUTIVE SUMMARY
This 90-Day Interim Report was prepared to provide the framework for
evaluating three types of remedial actions in controlling PCB-laden sediments
(greater than 50 ppm) in the Housatonic River Specifically the three types
of remedial actions are
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
This Interim Report is the second in a series of successive reports
prepared to address potential remedial alternatives for the Housatonic River
A previous report entitled the 45-Day Interim Report dated October 1984
(Reference 1) addressed the remedial alternative of dredging the PCB-laden
sediments from the river and disposing of these sediments in a local disposal
facility in accordance with Federal and State regulations
This 90-Day Interim Report provides a preliminary description of each of
the alternatives listed above along with establishing the engineering design
and construction considerations potential major environmental impacts and
estimated schedules for project completion A summary of the findings of this
report follows
FLOW AND VELOCITY CONTROL
The Flow and Velocity Control Alternative consists of modifying the
existing Schweitzer Dam below Woods Pond to further increase the ability of
- 1 shy
Woods Pond to act as a reliable and efficient sediment trap for PCB-laden
sediments (greater than 50 ppm) This may be accomplished by implementing
the following actions
1 Elimination of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
The purpose of these activities is to induce increased sediment deposition
in Woods Pond and inhibit resuspension and transport of the sediments to the
downstream river This is accomplished by reducing the water flow velocities
in Woods Pond and in the approach channel to the Schweitzer Dam
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Conduct safety and stability analyses of the dam and abutments
2 Structural design of selected flow and velocity control option
3 Development and design of a future reservoir drawdown system to
replace existing raceway and
H Development of a method to reduce the potential for sediment
movement during construction activities
It is estimated that the overall implementation schedule for any of the
flow and velocity control alternatives would be two years
RIVER CHANNELIZATION
The River Channelization Alternative consists of re-routing portions of
the Housatonic River by means of a new channel such that the river flow
does not contact PCB-laden sediments (greater than 50 ppm) This new river
channel is intended to connect river segments with known non-PCB-laden
sediments while bypassing those segments with known PCB-laden sediments
(greater than 50 ppm)
The major engineering design and environmental considerations associated
with this alternative and summarized below
1 Development of a technique(s) to drain those areas being bypassed
2 Determination of the acceptability of excavated soils as embankment
materials
3 Determination of location of spoil or disposal areas for excess
excavated materials
4 Evaluation of potential flood storage volume impacts
5 Evaluation of potential groundwater and surface water impacts
6 Evaluation of environmental impacts upon the wetland areas
associated with Woods Pond and the backwater areas
7 Evaluation of construction activities upon local transportation
routes
8 Evaluation of impact upon recreational activities within the
Housatonic River Wildlife Management Area and
9 Evaluation of the impacts of construction activities upon the local
public
- 3 shy
It is estimated that the overall implementation schedule for the river
channelization alternative would be four years
IN-SITU IMPOUNDMENT
The In-situ Impoundment Alternative entails the in-place stabilization of
PCB-laden sediments (greater than 50 ppm) by either physical isolation
(armoring) or by the addition of binding materials (chemical stabilization) to
minimize sediment transport The armoring option consists of covering
PCB-laden sediments with granular materials such as sand and gravel and the
chemical stabilization option consists of using binding materials such as fly
ash or cement to combine with the sediments to form a hardened soil mass
thus reducing the potential for sediment transport
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
5 Identification of the strength required and methods necessary to
obtain a stable base
6 Development of an inspection program to evaluate and maintain the
effectiveness of this alternative
7 Development of a method to reduce the potential for sediment
movement during construction activities
8 Evaluation of environmental impacts upon the wetland and backwater
areas during installation of the armoring or stabilization materials
9 Evaluation of construction activities upon local transportation
routes
10 Evaluation of potential flood storage volume impacts and
11 Evaluation of impacts of construction activities upon the local
public
It is estimated that the overall implementation schedule for either in-situ
impoundment alternative would be four to five years
For all remedial actions evaluated in this Interim Report there exist a
number of Federal State and local regulations which govern the various
remedial activities The appropriate regulations and review authorities are
identified for each alternative in this Report
The next report prepared the 135-Day Interim Report will present the
further evaluation of all the remedial alternatives presented within the 45shy
and 90-Day Interim Reports and will include recommendations for those
alternatives to be evaluated in greater detail withjn the final 210-Day Report
- 5 shy
Introduction BLASLAND amp BOUCK ENGINEERS PC
SECTION 2 - INTRODUCTION
21 General
This 90-Day Interim Report will present a preliminary evaluation of three
remedial action alternatives proposed to control PCB-laden sediments (greater
than 50 ppm) in the Housatonic River These three remedial action
alternatives are as follows
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
A previous report entitled the US-Day Interim Report (Reference 1)
dated October 1984 presented an evaluation of the sediment removal and local
disposal alternative and also provided detailed background information as to
the development of the four proposed alternatives being evaluated (the three
listed above and sediment removal)
The 135-Day Interim Report will further evaluate potentially adverse
environmental impacts and present additional engineering assessments of those
alternatives presented in the 45-Day and 90-Day Interim Reports The
135-Day Interim Report will also present recommendations for screening out
those alternatives which do not warrant any further detailed evaluation
because of their engineering effectiveness adverse environmental impacts
restrictive regulatory requirements or public reluctance
- 6 shy
22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
- 7 shy
Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
- 8 shy
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
DRAFT 1 1 1 5 8 4
Page No
Section 6 In-situ Impoundment Alternative 25
61 General 25
62 Description of Alternative 25
63 Pre-Construction and Construction Activities 27
64 Scheduling 28
65 Major Engineering Design Considerations 28
66 Major Potential Environmental Impacts 29
Section 7 Application of Regulations 32
71 Introduction 32
72 Federal Regulations 33
73 State Regulations 35
74 Local RegulationsRequirements 39
75 Summary 40
Section 8 Summary and Recommendations 42
81 Summary and Recommendations 42
References
ACKNOWLEDGEMENT
Portions of this report were prepared by other consultants
Specifically Erseco Inc prepared Sections 3 and 7 OBrien 6 Cere
Engineers Inc prepared Sections 4 and 6 and Dravo Van Houten Consulting
Engineers prepared Section 5 In addition Erseco Inc assisted Blasland amp
Bouck Engineers PC by providing general consultation and review
Executive Summary BLASLANO ft BOUCK ENGINEERS PO
SECTION 1 - EXECUTIVE SUMMARY
This 90-Day Interim Report was prepared to provide the framework for
evaluating three types of remedial actions in controlling PCB-laden sediments
(greater than 50 ppm) in the Housatonic River Specifically the three types
of remedial actions are
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
This Interim Report is the second in a series of successive reports
prepared to address potential remedial alternatives for the Housatonic River
A previous report entitled the 45-Day Interim Report dated October 1984
(Reference 1) addressed the remedial alternative of dredging the PCB-laden
sediments from the river and disposing of these sediments in a local disposal
facility in accordance with Federal and State regulations
This 90-Day Interim Report provides a preliminary description of each of
the alternatives listed above along with establishing the engineering design
and construction considerations potential major environmental impacts and
estimated schedules for project completion A summary of the findings of this
report follows
FLOW AND VELOCITY CONTROL
The Flow and Velocity Control Alternative consists of modifying the
existing Schweitzer Dam below Woods Pond to further increase the ability of
- 1 shy
Woods Pond to act as a reliable and efficient sediment trap for PCB-laden
sediments (greater than 50 ppm) This may be accomplished by implementing
the following actions
1 Elimination of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
The purpose of these activities is to induce increased sediment deposition
in Woods Pond and inhibit resuspension and transport of the sediments to the
downstream river This is accomplished by reducing the water flow velocities
in Woods Pond and in the approach channel to the Schweitzer Dam
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Conduct safety and stability analyses of the dam and abutments
2 Structural design of selected flow and velocity control option
3 Development and design of a future reservoir drawdown system to
replace existing raceway and
H Development of a method to reduce the potential for sediment
movement during construction activities
It is estimated that the overall implementation schedule for any of the
flow and velocity control alternatives would be two years
RIVER CHANNELIZATION
The River Channelization Alternative consists of re-routing portions of
the Housatonic River by means of a new channel such that the river flow
does not contact PCB-laden sediments (greater than 50 ppm) This new river
channel is intended to connect river segments with known non-PCB-laden
sediments while bypassing those segments with known PCB-laden sediments
(greater than 50 ppm)
The major engineering design and environmental considerations associated
with this alternative and summarized below
1 Development of a technique(s) to drain those areas being bypassed
2 Determination of the acceptability of excavated soils as embankment
materials
3 Determination of location of spoil or disposal areas for excess
excavated materials
4 Evaluation of potential flood storage volume impacts
5 Evaluation of potential groundwater and surface water impacts
6 Evaluation of environmental impacts upon the wetland areas
associated with Woods Pond and the backwater areas
7 Evaluation of construction activities upon local transportation
routes
8 Evaluation of impact upon recreational activities within the
Housatonic River Wildlife Management Area and
9 Evaluation of the impacts of construction activities upon the local
public
- 3 shy
It is estimated that the overall implementation schedule for the river
channelization alternative would be four years
IN-SITU IMPOUNDMENT
The In-situ Impoundment Alternative entails the in-place stabilization of
PCB-laden sediments (greater than 50 ppm) by either physical isolation
(armoring) or by the addition of binding materials (chemical stabilization) to
minimize sediment transport The armoring option consists of covering
PCB-laden sediments with granular materials such as sand and gravel and the
chemical stabilization option consists of using binding materials such as fly
ash or cement to combine with the sediments to form a hardened soil mass
thus reducing the potential for sediment transport
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
5 Identification of the strength required and methods necessary to
obtain a stable base
6 Development of an inspection program to evaluate and maintain the
effectiveness of this alternative
7 Development of a method to reduce the potential for sediment
movement during construction activities
8 Evaluation of environmental impacts upon the wetland and backwater
areas during installation of the armoring or stabilization materials
9 Evaluation of construction activities upon local transportation
routes
10 Evaluation of potential flood storage volume impacts and
11 Evaluation of impacts of construction activities upon the local
public
It is estimated that the overall implementation schedule for either in-situ
impoundment alternative would be four to five years
For all remedial actions evaluated in this Interim Report there exist a
number of Federal State and local regulations which govern the various
remedial activities The appropriate regulations and review authorities are
identified for each alternative in this Report
The next report prepared the 135-Day Interim Report will present the
further evaluation of all the remedial alternatives presented within the 45shy
and 90-Day Interim Reports and will include recommendations for those
alternatives to be evaluated in greater detail withjn the final 210-Day Report
- 5 shy
Introduction BLASLAND amp BOUCK ENGINEERS PC
SECTION 2 - INTRODUCTION
21 General
This 90-Day Interim Report will present a preliminary evaluation of three
remedial action alternatives proposed to control PCB-laden sediments (greater
than 50 ppm) in the Housatonic River These three remedial action
alternatives are as follows
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
A previous report entitled the US-Day Interim Report (Reference 1)
dated October 1984 presented an evaluation of the sediment removal and local
disposal alternative and also provided detailed background information as to
the development of the four proposed alternatives being evaluated (the three
listed above and sediment removal)
The 135-Day Interim Report will further evaluate potentially adverse
environmental impacts and present additional engineering assessments of those
alternatives presented in the 45-Day and 90-Day Interim Reports The
135-Day Interim Report will also present recommendations for screening out
those alternatives which do not warrant any further detailed evaluation
because of their engineering effectiveness adverse environmental impacts
restrictive regulatory requirements or public reluctance
- 6 shy
22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
- 7 shy
Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
- 8 shy
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
ACKNOWLEDGEMENT
Portions of this report were prepared by other consultants
Specifically Erseco Inc prepared Sections 3 and 7 OBrien 6 Cere
Engineers Inc prepared Sections 4 and 6 and Dravo Van Houten Consulting
Engineers prepared Section 5 In addition Erseco Inc assisted Blasland amp
Bouck Engineers PC by providing general consultation and review
Executive Summary BLASLANO ft BOUCK ENGINEERS PO
SECTION 1 - EXECUTIVE SUMMARY
This 90-Day Interim Report was prepared to provide the framework for
evaluating three types of remedial actions in controlling PCB-laden sediments
(greater than 50 ppm) in the Housatonic River Specifically the three types
of remedial actions are
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
This Interim Report is the second in a series of successive reports
prepared to address potential remedial alternatives for the Housatonic River
A previous report entitled the 45-Day Interim Report dated October 1984
(Reference 1) addressed the remedial alternative of dredging the PCB-laden
sediments from the river and disposing of these sediments in a local disposal
facility in accordance with Federal and State regulations
This 90-Day Interim Report provides a preliminary description of each of
the alternatives listed above along with establishing the engineering design
and construction considerations potential major environmental impacts and
estimated schedules for project completion A summary of the findings of this
report follows
FLOW AND VELOCITY CONTROL
The Flow and Velocity Control Alternative consists of modifying the
existing Schweitzer Dam below Woods Pond to further increase the ability of
- 1 shy
Woods Pond to act as a reliable and efficient sediment trap for PCB-laden
sediments (greater than 50 ppm) This may be accomplished by implementing
the following actions
1 Elimination of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
The purpose of these activities is to induce increased sediment deposition
in Woods Pond and inhibit resuspension and transport of the sediments to the
downstream river This is accomplished by reducing the water flow velocities
in Woods Pond and in the approach channel to the Schweitzer Dam
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Conduct safety and stability analyses of the dam and abutments
2 Structural design of selected flow and velocity control option
3 Development and design of a future reservoir drawdown system to
replace existing raceway and
H Development of a method to reduce the potential for sediment
movement during construction activities
It is estimated that the overall implementation schedule for any of the
flow and velocity control alternatives would be two years
RIVER CHANNELIZATION
The River Channelization Alternative consists of re-routing portions of
the Housatonic River by means of a new channel such that the river flow
does not contact PCB-laden sediments (greater than 50 ppm) This new river
channel is intended to connect river segments with known non-PCB-laden
sediments while bypassing those segments with known PCB-laden sediments
(greater than 50 ppm)
The major engineering design and environmental considerations associated
with this alternative and summarized below
1 Development of a technique(s) to drain those areas being bypassed
2 Determination of the acceptability of excavated soils as embankment
materials
3 Determination of location of spoil or disposal areas for excess
excavated materials
4 Evaluation of potential flood storage volume impacts
5 Evaluation of potential groundwater and surface water impacts
6 Evaluation of environmental impacts upon the wetland areas
associated with Woods Pond and the backwater areas
7 Evaluation of construction activities upon local transportation
routes
8 Evaluation of impact upon recreational activities within the
Housatonic River Wildlife Management Area and
9 Evaluation of the impacts of construction activities upon the local
public
- 3 shy
It is estimated that the overall implementation schedule for the river
channelization alternative would be four years
IN-SITU IMPOUNDMENT
The In-situ Impoundment Alternative entails the in-place stabilization of
PCB-laden sediments (greater than 50 ppm) by either physical isolation
(armoring) or by the addition of binding materials (chemical stabilization) to
minimize sediment transport The armoring option consists of covering
PCB-laden sediments with granular materials such as sand and gravel and the
chemical stabilization option consists of using binding materials such as fly
ash or cement to combine with the sediments to form a hardened soil mass
thus reducing the potential for sediment transport
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
5 Identification of the strength required and methods necessary to
obtain a stable base
6 Development of an inspection program to evaluate and maintain the
effectiveness of this alternative
7 Development of a method to reduce the potential for sediment
movement during construction activities
8 Evaluation of environmental impacts upon the wetland and backwater
areas during installation of the armoring or stabilization materials
9 Evaluation of construction activities upon local transportation
routes
10 Evaluation of potential flood storage volume impacts and
11 Evaluation of impacts of construction activities upon the local
public
It is estimated that the overall implementation schedule for either in-situ
impoundment alternative would be four to five years
For all remedial actions evaluated in this Interim Report there exist a
number of Federal State and local regulations which govern the various
remedial activities The appropriate regulations and review authorities are
identified for each alternative in this Report
The next report prepared the 135-Day Interim Report will present the
further evaluation of all the remedial alternatives presented within the 45shy
and 90-Day Interim Reports and will include recommendations for those
alternatives to be evaluated in greater detail withjn the final 210-Day Report
- 5 shy
Introduction BLASLAND amp BOUCK ENGINEERS PC
SECTION 2 - INTRODUCTION
21 General
This 90-Day Interim Report will present a preliminary evaluation of three
remedial action alternatives proposed to control PCB-laden sediments (greater
than 50 ppm) in the Housatonic River These three remedial action
alternatives are as follows
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
A previous report entitled the US-Day Interim Report (Reference 1)
dated October 1984 presented an evaluation of the sediment removal and local
disposal alternative and also provided detailed background information as to
the development of the four proposed alternatives being evaluated (the three
listed above and sediment removal)
The 135-Day Interim Report will further evaluate potentially adverse
environmental impacts and present additional engineering assessments of those
alternatives presented in the 45-Day and 90-Day Interim Reports The
135-Day Interim Report will also present recommendations for screening out
those alternatives which do not warrant any further detailed evaluation
because of their engineering effectiveness adverse environmental impacts
restrictive regulatory requirements or public reluctance
- 6 shy
22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
- 7 shy
Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
- 8 shy
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
Executive Summary BLASLANO ft BOUCK ENGINEERS PO
SECTION 1 - EXECUTIVE SUMMARY
This 90-Day Interim Report was prepared to provide the framework for
evaluating three types of remedial actions in controlling PCB-laden sediments
(greater than 50 ppm) in the Housatonic River Specifically the three types
of remedial actions are
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
This Interim Report is the second in a series of successive reports
prepared to address potential remedial alternatives for the Housatonic River
A previous report entitled the 45-Day Interim Report dated October 1984
(Reference 1) addressed the remedial alternative of dredging the PCB-laden
sediments from the river and disposing of these sediments in a local disposal
facility in accordance with Federal and State regulations
This 90-Day Interim Report provides a preliminary description of each of
the alternatives listed above along with establishing the engineering design
and construction considerations potential major environmental impacts and
estimated schedules for project completion A summary of the findings of this
report follows
FLOW AND VELOCITY CONTROL
The Flow and Velocity Control Alternative consists of modifying the
existing Schweitzer Dam below Woods Pond to further increase the ability of
- 1 shy
Woods Pond to act as a reliable and efficient sediment trap for PCB-laden
sediments (greater than 50 ppm) This may be accomplished by implementing
the following actions
1 Elimination of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
The purpose of these activities is to induce increased sediment deposition
in Woods Pond and inhibit resuspension and transport of the sediments to the
downstream river This is accomplished by reducing the water flow velocities
in Woods Pond and in the approach channel to the Schweitzer Dam
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Conduct safety and stability analyses of the dam and abutments
2 Structural design of selected flow and velocity control option
3 Development and design of a future reservoir drawdown system to
replace existing raceway and
H Development of a method to reduce the potential for sediment
movement during construction activities
It is estimated that the overall implementation schedule for any of the
flow and velocity control alternatives would be two years
RIVER CHANNELIZATION
The River Channelization Alternative consists of re-routing portions of
the Housatonic River by means of a new channel such that the river flow
does not contact PCB-laden sediments (greater than 50 ppm) This new river
channel is intended to connect river segments with known non-PCB-laden
sediments while bypassing those segments with known PCB-laden sediments
(greater than 50 ppm)
The major engineering design and environmental considerations associated
with this alternative and summarized below
1 Development of a technique(s) to drain those areas being bypassed
2 Determination of the acceptability of excavated soils as embankment
materials
3 Determination of location of spoil or disposal areas for excess
excavated materials
4 Evaluation of potential flood storage volume impacts
5 Evaluation of potential groundwater and surface water impacts
6 Evaluation of environmental impacts upon the wetland areas
associated with Woods Pond and the backwater areas
7 Evaluation of construction activities upon local transportation
routes
8 Evaluation of impact upon recreational activities within the
Housatonic River Wildlife Management Area and
9 Evaluation of the impacts of construction activities upon the local
public
- 3 shy
It is estimated that the overall implementation schedule for the river
channelization alternative would be four years
IN-SITU IMPOUNDMENT
The In-situ Impoundment Alternative entails the in-place stabilization of
PCB-laden sediments (greater than 50 ppm) by either physical isolation
(armoring) or by the addition of binding materials (chemical stabilization) to
minimize sediment transport The armoring option consists of covering
PCB-laden sediments with granular materials such as sand and gravel and the
chemical stabilization option consists of using binding materials such as fly
ash or cement to combine with the sediments to form a hardened soil mass
thus reducing the potential for sediment transport
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
5 Identification of the strength required and methods necessary to
obtain a stable base
6 Development of an inspection program to evaluate and maintain the
effectiveness of this alternative
7 Development of a method to reduce the potential for sediment
movement during construction activities
8 Evaluation of environmental impacts upon the wetland and backwater
areas during installation of the armoring or stabilization materials
9 Evaluation of construction activities upon local transportation
routes
10 Evaluation of potential flood storage volume impacts and
11 Evaluation of impacts of construction activities upon the local
public
It is estimated that the overall implementation schedule for either in-situ
impoundment alternative would be four to five years
For all remedial actions evaluated in this Interim Report there exist a
number of Federal State and local regulations which govern the various
remedial activities The appropriate regulations and review authorities are
identified for each alternative in this Report
The next report prepared the 135-Day Interim Report will present the
further evaluation of all the remedial alternatives presented within the 45shy
and 90-Day Interim Reports and will include recommendations for those
alternatives to be evaluated in greater detail withjn the final 210-Day Report
- 5 shy
Introduction BLASLAND amp BOUCK ENGINEERS PC
SECTION 2 - INTRODUCTION
21 General
This 90-Day Interim Report will present a preliminary evaluation of three
remedial action alternatives proposed to control PCB-laden sediments (greater
than 50 ppm) in the Housatonic River These three remedial action
alternatives are as follows
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
A previous report entitled the US-Day Interim Report (Reference 1)
dated October 1984 presented an evaluation of the sediment removal and local
disposal alternative and also provided detailed background information as to
the development of the four proposed alternatives being evaluated (the three
listed above and sediment removal)
The 135-Day Interim Report will further evaluate potentially adverse
environmental impacts and present additional engineering assessments of those
alternatives presented in the 45-Day and 90-Day Interim Reports The
135-Day Interim Report will also present recommendations for screening out
those alternatives which do not warrant any further detailed evaluation
because of their engineering effectiveness adverse environmental impacts
restrictive regulatory requirements or public reluctance
- 6 shy
22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
- 7 shy
Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
- 8 shy
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
SECTION 1 - EXECUTIVE SUMMARY
This 90-Day Interim Report was prepared to provide the framework for
evaluating three types of remedial actions in controlling PCB-laden sediments
(greater than 50 ppm) in the Housatonic River Specifically the three types
of remedial actions are
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
This Interim Report is the second in a series of successive reports
prepared to address potential remedial alternatives for the Housatonic River
A previous report entitled the 45-Day Interim Report dated October 1984
(Reference 1) addressed the remedial alternative of dredging the PCB-laden
sediments from the river and disposing of these sediments in a local disposal
facility in accordance with Federal and State regulations
This 90-Day Interim Report provides a preliminary description of each of
the alternatives listed above along with establishing the engineering design
and construction considerations potential major environmental impacts and
estimated schedules for project completion A summary of the findings of this
report follows
FLOW AND VELOCITY CONTROL
The Flow and Velocity Control Alternative consists of modifying the
existing Schweitzer Dam below Woods Pond to further increase the ability of
- 1 shy
Woods Pond to act as a reliable and efficient sediment trap for PCB-laden
sediments (greater than 50 ppm) This may be accomplished by implementing
the following actions
1 Elimination of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
The purpose of these activities is to induce increased sediment deposition
in Woods Pond and inhibit resuspension and transport of the sediments to the
downstream river This is accomplished by reducing the water flow velocities
in Woods Pond and in the approach channel to the Schweitzer Dam
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Conduct safety and stability analyses of the dam and abutments
2 Structural design of selected flow and velocity control option
3 Development and design of a future reservoir drawdown system to
replace existing raceway and
H Development of a method to reduce the potential for sediment
movement during construction activities
It is estimated that the overall implementation schedule for any of the
flow and velocity control alternatives would be two years
RIVER CHANNELIZATION
The River Channelization Alternative consists of re-routing portions of
the Housatonic River by means of a new channel such that the river flow
does not contact PCB-laden sediments (greater than 50 ppm) This new river
channel is intended to connect river segments with known non-PCB-laden
sediments while bypassing those segments with known PCB-laden sediments
(greater than 50 ppm)
The major engineering design and environmental considerations associated
with this alternative and summarized below
1 Development of a technique(s) to drain those areas being bypassed
2 Determination of the acceptability of excavated soils as embankment
materials
3 Determination of location of spoil or disposal areas for excess
excavated materials
4 Evaluation of potential flood storage volume impacts
5 Evaluation of potential groundwater and surface water impacts
6 Evaluation of environmental impacts upon the wetland areas
associated with Woods Pond and the backwater areas
7 Evaluation of construction activities upon local transportation
routes
8 Evaluation of impact upon recreational activities within the
Housatonic River Wildlife Management Area and
9 Evaluation of the impacts of construction activities upon the local
public
- 3 shy
It is estimated that the overall implementation schedule for the river
channelization alternative would be four years
IN-SITU IMPOUNDMENT
The In-situ Impoundment Alternative entails the in-place stabilization of
PCB-laden sediments (greater than 50 ppm) by either physical isolation
(armoring) or by the addition of binding materials (chemical stabilization) to
minimize sediment transport The armoring option consists of covering
PCB-laden sediments with granular materials such as sand and gravel and the
chemical stabilization option consists of using binding materials such as fly
ash or cement to combine with the sediments to form a hardened soil mass
thus reducing the potential for sediment transport
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
5 Identification of the strength required and methods necessary to
obtain a stable base
6 Development of an inspection program to evaluate and maintain the
effectiveness of this alternative
7 Development of a method to reduce the potential for sediment
movement during construction activities
8 Evaluation of environmental impacts upon the wetland and backwater
areas during installation of the armoring or stabilization materials
9 Evaluation of construction activities upon local transportation
routes
10 Evaluation of potential flood storage volume impacts and
11 Evaluation of impacts of construction activities upon the local
public
It is estimated that the overall implementation schedule for either in-situ
impoundment alternative would be four to five years
For all remedial actions evaluated in this Interim Report there exist a
number of Federal State and local regulations which govern the various
remedial activities The appropriate regulations and review authorities are
identified for each alternative in this Report
The next report prepared the 135-Day Interim Report will present the
further evaluation of all the remedial alternatives presented within the 45shy
and 90-Day Interim Reports and will include recommendations for those
alternatives to be evaluated in greater detail withjn the final 210-Day Report
- 5 shy
Introduction BLASLAND amp BOUCK ENGINEERS PC
SECTION 2 - INTRODUCTION
21 General
This 90-Day Interim Report will present a preliminary evaluation of three
remedial action alternatives proposed to control PCB-laden sediments (greater
than 50 ppm) in the Housatonic River These three remedial action
alternatives are as follows
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
A previous report entitled the US-Day Interim Report (Reference 1)
dated October 1984 presented an evaluation of the sediment removal and local
disposal alternative and also provided detailed background information as to
the development of the four proposed alternatives being evaluated (the three
listed above and sediment removal)
The 135-Day Interim Report will further evaluate potentially adverse
environmental impacts and present additional engineering assessments of those
alternatives presented in the 45-Day and 90-Day Interim Reports The
135-Day Interim Report will also present recommendations for screening out
those alternatives which do not warrant any further detailed evaluation
because of their engineering effectiveness adverse environmental impacts
restrictive regulatory requirements or public reluctance
- 6 shy
22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
- 7 shy
Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
- 8 shy
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
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There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
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34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
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The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
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Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
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FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
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end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
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FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
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1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
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46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
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River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
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SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
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FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
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3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
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In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
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FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
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FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
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FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
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1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
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chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
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5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
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Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
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72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
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implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
Woods Pond to act as a reliable and efficient sediment trap for PCB-laden
sediments (greater than 50 ppm) This may be accomplished by implementing
the following actions
1 Elimination of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
The purpose of these activities is to induce increased sediment deposition
in Woods Pond and inhibit resuspension and transport of the sediments to the
downstream river This is accomplished by reducing the water flow velocities
in Woods Pond and in the approach channel to the Schweitzer Dam
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Conduct safety and stability analyses of the dam and abutments
2 Structural design of selected flow and velocity control option
3 Development and design of a future reservoir drawdown system to
replace existing raceway and
H Development of a method to reduce the potential for sediment
movement during construction activities
It is estimated that the overall implementation schedule for any of the
flow and velocity control alternatives would be two years
RIVER CHANNELIZATION
The River Channelization Alternative consists of re-routing portions of
the Housatonic River by means of a new channel such that the river flow
does not contact PCB-laden sediments (greater than 50 ppm) This new river
channel is intended to connect river segments with known non-PCB-laden
sediments while bypassing those segments with known PCB-laden sediments
(greater than 50 ppm)
The major engineering design and environmental considerations associated
with this alternative and summarized below
1 Development of a technique(s) to drain those areas being bypassed
2 Determination of the acceptability of excavated soils as embankment
materials
3 Determination of location of spoil or disposal areas for excess
excavated materials
4 Evaluation of potential flood storage volume impacts
5 Evaluation of potential groundwater and surface water impacts
6 Evaluation of environmental impacts upon the wetland areas
associated with Woods Pond and the backwater areas
7 Evaluation of construction activities upon local transportation
routes
8 Evaluation of impact upon recreational activities within the
Housatonic River Wildlife Management Area and
9 Evaluation of the impacts of construction activities upon the local
public
- 3 shy
It is estimated that the overall implementation schedule for the river
channelization alternative would be four years
IN-SITU IMPOUNDMENT
The In-situ Impoundment Alternative entails the in-place stabilization of
PCB-laden sediments (greater than 50 ppm) by either physical isolation
(armoring) or by the addition of binding materials (chemical stabilization) to
minimize sediment transport The armoring option consists of covering
PCB-laden sediments with granular materials such as sand and gravel and the
chemical stabilization option consists of using binding materials such as fly
ash or cement to combine with the sediments to form a hardened soil mass
thus reducing the potential for sediment transport
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
5 Identification of the strength required and methods necessary to
obtain a stable base
6 Development of an inspection program to evaluate and maintain the
effectiveness of this alternative
7 Development of a method to reduce the potential for sediment
movement during construction activities
8 Evaluation of environmental impacts upon the wetland and backwater
areas during installation of the armoring or stabilization materials
9 Evaluation of construction activities upon local transportation
routes
10 Evaluation of potential flood storage volume impacts and
11 Evaluation of impacts of construction activities upon the local
public
It is estimated that the overall implementation schedule for either in-situ
impoundment alternative would be four to five years
For all remedial actions evaluated in this Interim Report there exist a
number of Federal State and local regulations which govern the various
remedial activities The appropriate regulations and review authorities are
identified for each alternative in this Report
The next report prepared the 135-Day Interim Report will present the
further evaluation of all the remedial alternatives presented within the 45shy
and 90-Day Interim Reports and will include recommendations for those
alternatives to be evaluated in greater detail withjn the final 210-Day Report
- 5 shy
Introduction BLASLAND amp BOUCK ENGINEERS PC
SECTION 2 - INTRODUCTION
21 General
This 90-Day Interim Report will present a preliminary evaluation of three
remedial action alternatives proposed to control PCB-laden sediments (greater
than 50 ppm) in the Housatonic River These three remedial action
alternatives are as follows
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
A previous report entitled the US-Day Interim Report (Reference 1)
dated October 1984 presented an evaluation of the sediment removal and local
disposal alternative and also provided detailed background information as to
the development of the four proposed alternatives being evaluated (the three
listed above and sediment removal)
The 135-Day Interim Report will further evaluate potentially adverse
environmental impacts and present additional engineering assessments of those
alternatives presented in the 45-Day and 90-Day Interim Reports The
135-Day Interim Report will also present recommendations for screening out
those alternatives which do not warrant any further detailed evaluation
because of their engineering effectiveness adverse environmental impacts
restrictive regulatory requirements or public reluctance
- 6 shy
22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
- 7 shy
Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
- 8 shy
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
RIVER CHANNELIZATION
The River Channelization Alternative consists of re-routing portions of
the Housatonic River by means of a new channel such that the river flow
does not contact PCB-laden sediments (greater than 50 ppm) This new river
channel is intended to connect river segments with known non-PCB-laden
sediments while bypassing those segments with known PCB-laden sediments
(greater than 50 ppm)
The major engineering design and environmental considerations associated
with this alternative and summarized below
1 Development of a technique(s) to drain those areas being bypassed
2 Determination of the acceptability of excavated soils as embankment
materials
3 Determination of location of spoil or disposal areas for excess
excavated materials
4 Evaluation of potential flood storage volume impacts
5 Evaluation of potential groundwater and surface water impacts
6 Evaluation of environmental impacts upon the wetland areas
associated with Woods Pond and the backwater areas
7 Evaluation of construction activities upon local transportation
routes
8 Evaluation of impact upon recreational activities within the
Housatonic River Wildlife Management Area and
9 Evaluation of the impacts of construction activities upon the local
public
- 3 shy
It is estimated that the overall implementation schedule for the river
channelization alternative would be four years
IN-SITU IMPOUNDMENT
The In-situ Impoundment Alternative entails the in-place stabilization of
PCB-laden sediments (greater than 50 ppm) by either physical isolation
(armoring) or by the addition of binding materials (chemical stabilization) to
minimize sediment transport The armoring option consists of covering
PCB-laden sediments with granular materials such as sand and gravel and the
chemical stabilization option consists of using binding materials such as fly
ash or cement to combine with the sediments to form a hardened soil mass
thus reducing the potential for sediment transport
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
5 Identification of the strength required and methods necessary to
obtain a stable base
6 Development of an inspection program to evaluate and maintain the
effectiveness of this alternative
7 Development of a method to reduce the potential for sediment
movement during construction activities
8 Evaluation of environmental impacts upon the wetland and backwater
areas during installation of the armoring or stabilization materials
9 Evaluation of construction activities upon local transportation
routes
10 Evaluation of potential flood storage volume impacts and
11 Evaluation of impacts of construction activities upon the local
public
It is estimated that the overall implementation schedule for either in-situ
impoundment alternative would be four to five years
For all remedial actions evaluated in this Interim Report there exist a
number of Federal State and local regulations which govern the various
remedial activities The appropriate regulations and review authorities are
identified for each alternative in this Report
The next report prepared the 135-Day Interim Report will present the
further evaluation of all the remedial alternatives presented within the 45shy
and 90-Day Interim Reports and will include recommendations for those
alternatives to be evaluated in greater detail withjn the final 210-Day Report
- 5 shy
Introduction BLASLAND amp BOUCK ENGINEERS PC
SECTION 2 - INTRODUCTION
21 General
This 90-Day Interim Report will present a preliminary evaluation of three
remedial action alternatives proposed to control PCB-laden sediments (greater
than 50 ppm) in the Housatonic River These three remedial action
alternatives are as follows
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
A previous report entitled the US-Day Interim Report (Reference 1)
dated October 1984 presented an evaluation of the sediment removal and local
disposal alternative and also provided detailed background information as to
the development of the four proposed alternatives being evaluated (the three
listed above and sediment removal)
The 135-Day Interim Report will further evaluate potentially adverse
environmental impacts and present additional engineering assessments of those
alternatives presented in the 45-Day and 90-Day Interim Reports The
135-Day Interim Report will also present recommendations for screening out
those alternatives which do not warrant any further detailed evaluation
because of their engineering effectiveness adverse environmental impacts
restrictive regulatory requirements or public reluctance
- 6 shy
22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
- 7 shy
Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
- 8 shy
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
It is estimated that the overall implementation schedule for the river
channelization alternative would be four years
IN-SITU IMPOUNDMENT
The In-situ Impoundment Alternative entails the in-place stabilization of
PCB-laden sediments (greater than 50 ppm) by either physical isolation
(armoring) or by the addition of binding materials (chemical stabilization) to
minimize sediment transport The armoring option consists of covering
PCB-laden sediments with granular materials such as sand and gravel and the
chemical stabilization option consists of using binding materials such as fly
ash or cement to combine with the sediments to form a hardened soil mass
thus reducing the potential for sediment transport
The major engineering design and environmental considerations associated
with this alternative are summarized below
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
5 Identification of the strength required and methods necessary to
obtain a stable base
6 Development of an inspection program to evaluate and maintain the
effectiveness of this alternative
7 Development of a method to reduce the potential for sediment
movement during construction activities
8 Evaluation of environmental impacts upon the wetland and backwater
areas during installation of the armoring or stabilization materials
9 Evaluation of construction activities upon local transportation
routes
10 Evaluation of potential flood storage volume impacts and
11 Evaluation of impacts of construction activities upon the local
public
It is estimated that the overall implementation schedule for either in-situ
impoundment alternative would be four to five years
For all remedial actions evaluated in this Interim Report there exist a
number of Federal State and local regulations which govern the various
remedial activities The appropriate regulations and review authorities are
identified for each alternative in this Report
The next report prepared the 135-Day Interim Report will present the
further evaluation of all the remedial alternatives presented within the 45shy
and 90-Day Interim Reports and will include recommendations for those
alternatives to be evaluated in greater detail withjn the final 210-Day Report
- 5 shy
Introduction BLASLAND amp BOUCK ENGINEERS PC
SECTION 2 - INTRODUCTION
21 General
This 90-Day Interim Report will present a preliminary evaluation of three
remedial action alternatives proposed to control PCB-laden sediments (greater
than 50 ppm) in the Housatonic River These three remedial action
alternatives are as follows
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
A previous report entitled the US-Day Interim Report (Reference 1)
dated October 1984 presented an evaluation of the sediment removal and local
disposal alternative and also provided detailed background information as to
the development of the four proposed alternatives being evaluated (the three
listed above and sediment removal)
The 135-Day Interim Report will further evaluate potentially adverse
environmental impacts and present additional engineering assessments of those
alternatives presented in the 45-Day and 90-Day Interim Reports The
135-Day Interim Report will also present recommendations for screening out
those alternatives which do not warrant any further detailed evaluation
because of their engineering effectiveness adverse environmental impacts
restrictive regulatory requirements or public reluctance
- 6 shy
22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
- 7 shy
Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
- 8 shy
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
7 Development of a method to reduce the potential for sediment
movement during construction activities
8 Evaluation of environmental impacts upon the wetland and backwater
areas during installation of the armoring or stabilization materials
9 Evaluation of construction activities upon local transportation
routes
10 Evaluation of potential flood storage volume impacts and
11 Evaluation of impacts of construction activities upon the local
public
It is estimated that the overall implementation schedule for either in-situ
impoundment alternative would be four to five years
For all remedial actions evaluated in this Interim Report there exist a
number of Federal State and local regulations which govern the various
remedial activities The appropriate regulations and review authorities are
identified for each alternative in this Report
The next report prepared the 135-Day Interim Report will present the
further evaluation of all the remedial alternatives presented within the 45shy
and 90-Day Interim Reports and will include recommendations for those
alternatives to be evaluated in greater detail withjn the final 210-Day Report
- 5 shy
Introduction BLASLAND amp BOUCK ENGINEERS PC
SECTION 2 - INTRODUCTION
21 General
This 90-Day Interim Report will present a preliminary evaluation of three
remedial action alternatives proposed to control PCB-laden sediments (greater
than 50 ppm) in the Housatonic River These three remedial action
alternatives are as follows
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
A previous report entitled the US-Day Interim Report (Reference 1)
dated October 1984 presented an evaluation of the sediment removal and local
disposal alternative and also provided detailed background information as to
the development of the four proposed alternatives being evaluated (the three
listed above and sediment removal)
The 135-Day Interim Report will further evaluate potentially adverse
environmental impacts and present additional engineering assessments of those
alternatives presented in the 45-Day and 90-Day Interim Reports The
135-Day Interim Report will also present recommendations for screening out
those alternatives which do not warrant any further detailed evaluation
because of their engineering effectiveness adverse environmental impacts
restrictive regulatory requirements or public reluctance
- 6 shy
22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
- 7 shy
Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
- 8 shy
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
Introduction BLASLAND amp BOUCK ENGINEERS PC
SECTION 2 - INTRODUCTION
21 General
This 90-Day Interim Report will present a preliminary evaluation of three
remedial action alternatives proposed to control PCB-laden sediments (greater
than 50 ppm) in the Housatonic River These three remedial action
alternatives are as follows
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
A previous report entitled the US-Day Interim Report (Reference 1)
dated October 1984 presented an evaluation of the sediment removal and local
disposal alternative and also provided detailed background information as to
the development of the four proposed alternatives being evaluated (the three
listed above and sediment removal)
The 135-Day Interim Report will further evaluate potentially adverse
environmental impacts and present additional engineering assessments of those
alternatives presented in the 45-Day and 90-Day Interim Reports The
135-Day Interim Report will also present recommendations for screening out
those alternatives which do not warrant any further detailed evaluation
because of their engineering effectiveness adverse environmental impacts
restrictive regulatory requirements or public reluctance
- 6 shy
22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
- 7 shy
Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
- 8 shy
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
SECTION 2 - INTRODUCTION
21 General
This 90-Day Interim Report will present a preliminary evaluation of three
remedial action alternatives proposed to control PCB-laden sediments (greater
than 50 ppm) in the Housatonic River These three remedial action
alternatives are as follows
1 Flow and Velocity Control
2 River Channelization and
3 In-situ Impoundment
A previous report entitled the US-Day Interim Report (Reference 1)
dated October 1984 presented an evaluation of the sediment removal and local
disposal alternative and also provided detailed background information as to
the development of the four proposed alternatives being evaluated (the three
listed above and sediment removal)
The 135-Day Interim Report will further evaluate potentially adverse
environmental impacts and present additional engineering assessments of those
alternatives presented in the 45-Day and 90-Day Interim Reports The
135-Day Interim Report will also present recommendations for screening out
those alternatives which do not warrant any further detailed evaluation
because of their engineering effectiveness adverse environmental impacts
restrictive regulatory requirements or public reluctance
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22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
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Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
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Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
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There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
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34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
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The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
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Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
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FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
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end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
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FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
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1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
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46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
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River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
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SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
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FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
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3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
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In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
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FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
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FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
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FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
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1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
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Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
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72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
22 Purpose and Scope of This Work Effort
In July 1984 General Electric contracted Blasland 5 Bouck Engineers
PC to prepare this Report including coordinating the efforts of Erseco
Inc OBrien amp Cere Engineers Inc and Dravo Van Houten Consulting
Engineers This Report contains the preliminary evaluation of the remaining
three remedial alternatives Flow and Velocity Control River Channelization
and In-situ Impoundment including an evaluation of construction activities
scheduling major engineering design considerations major potential
environmental impacts and identification of applicable Federal State and local
regulatory requirements for each remedial alternative
23 PCB-laden Sediments - Location and Description
Sediment distribution throughout the study area and the quantity of
sediment in each river section is described below
Location of PCB-Laden Sediments
The locations and estimated volume of PCB-laden sediments
(concentrations greater than 50 ppm) as identified in the Housatonic River
Study - 1980 and 1982 Investigations (2 volumes) prepared by Stewart
Laboratories Inc of Knoxville Tennessee hereafter referred to as the
Stewart Report (Reference 2) are as shown on Figure 1
- 7 shy
Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
- 8 shy
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
Description of Sediment Characteristics
According to the Stewart Report the sediments found within the study
area vary in physical characteristics Generally in the quiet shallow waters
of the river and its backwaters (formed by trapped flood waters behind the
river banks) and swamp areas the sediments consist of finer-grained
particles The particle size distribution of these finer-grained materials nay
range from coarse to fine sands to soft silts and clays Quite often these
sediments are mixed with highly organic material The sediments found in the
faster moving channels of the river consist of mainly coarse to fine sands and
gravels with cobbles
A more detailed description of sediment characteristics can be found in
Section 42b of the 45-Day Interim Report
- 8 shy
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
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34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
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The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
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Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
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FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
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end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
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FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
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1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
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46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
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River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
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SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
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FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
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3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
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In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
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FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
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FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
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FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
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1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
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5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
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Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
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72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
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Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
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75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
Overview of Appicabte Regulations
IIASLANO ft BOUCK ENGINEERS PC
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
SECTION 3 - OVERVIEW OF APPLICABLE REGULATIONS
31 Introduction
Assessment of the three remediat alternatives Flow and Velocity
Control River Channelization and In-situ Impoundment requires a thorough
understanding of the engineering constraints environmental effects and
potential community impacts associated with each of the alternatives As part
of the evaluation process it has become apparent that a review and
interpretation of the applicable Federal State and local regulations and
permitting requirements is necessary These regulations and requirements
impose design evaluation and administrative concerns which nust be
addressed in the initial phases of a feasibility study to ensure adequate
consideration is given to the various statutory interests
In addition to the applicable regulations and the criteria set forth in the
Consent Orders the actions taken on the local level and nationwide by the
EPA and individual states in similar situations are also examined The
appropriateness of using precedent-setting decisions and the accompanying
remedial actions selected are expressly stated in the National Contingency
Plan (NCP) Regulatory interests NCP criteria and previous PCB clean-up
feasibility studies will be discussed in this section
32 Regulatory Interests
The remedial technologies being evaluated for the Housatonic River
involve actions which by their nature initiate regulatory actions by various
governmental agencies
- 9 shy
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
There are numerous Federal and State statutes under which particular
actions associated with river channelization in-situ impoundment and no
action (dam improvement only) may be regulated including but not limited to
the NCR the Clean Water Act (CWA) and the Toxic Substances Control Act
(TSCA) at the Federal level and the Massachusetts Wetlands Protection Act
(WPA) at the State level Numerous local bylaws and ordinances also must be
adhered to when work is undertaken in each of the three affected
municipalities (City of Pittsfield Town of Lee and Town of Lenox) These
laws and associated regulations set forth technical criteria performance
standards and permitting requirements for projects involving a variety of
activities which may affect public health welfare and the environment
As a result of the relatively few precedent-setting cases involving the
clean-up of sensitive environmental areas such as the Housatonic River
system many of the applicable regulations form a complex and often
conflicting network of administrative jurisdictions and permitting
requirements These conflicts must be resolved by the subject agencies prior
to final selection design and implementation of a remedial action plan
33 Application of the National Contingency Plan
The engineering evaluations of the alternatives presented herein are
generally based on the evaluation criteria suggested by the NCP and
presented in an Erseco Report entitled Proposed Engineering Evaluation of the
Selected Housatonic Remedial Alternatives May 1984 (Reference 3)
Furthermore as suggested by the NCP experience and approaches used in
similar situations by Federal and State agencies and private parties will be
considered during the Housatonic River remedial action planning
- 10 shy
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
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FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
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FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
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1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
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46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
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SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
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3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
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72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 11 shy
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
The New Bedford HarborAcushnet River Estuary system is also
comparable to the Housatonic River situation as both involve riverestuary
systems with deposits of PCB-laden sediment Four remedial actions were
proposed for the New Bedford Harbor PCB site in a fast-track feasibility
study performed by the NUS Corporation Several of the remedial actions
presented by NUS are similar to the river channelization and in-situ
impoundment alternatives presented in this report NUS proposed to
construct approximately 8000 feet of bypass channel to isolate the Acushnet
River Estuary from the contaminated harbor bottom sediment In addition to
the bypass channel the harbor bottom in the remaining open water area
would be covered with clean sediment in order to isolate the contaminated
sediments from the water column The remedial actions proposed for New
Bedford Harbor have been presented to EPA for review As a result of this
review EPA will select one of the alternatives which may eventually be
implemented as the Superfund clean-up plan
The feasibility studies for both the Waukegan Harbor and the New
Bedford Harbor sites evaluated potential remedial alternatives for clean-up in
terms of engineering feasibility criteria environmental impacts costs and
other considerations It should be noted that no single alternative was found
to be free of engineering constraints adverse environmental effects and
potential community impacts
The technical knowledge experiences and application of environmental
regulations in these and other sites has been used as guidance in the
development of alternatives and regulatory processes required for the
Housatonic River
- 12shy
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
Row and Velocity Control Alternative
BLASUND ft BOUCK ENGINEERS PC
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
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FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
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1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
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46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
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River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
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SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
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FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
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3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
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In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
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FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
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FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
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FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
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1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
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5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
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Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
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72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
SECTION U - FLOW AND VELOCITY CONTROL ALTERNATIVE
General
This section will present the prelininary evaluation of the Flow and
Velocity Control Alternative being considered for Schweitzer Dam The
objective of this alternative is to perform appropriate improvements to the
Schweitzer Dam which would further increase the ability of Woods Pond to
act as a reliable effective trap and permanent repository for PCB-laden
sediments Presented within this section is a description of the alternative as
well as a preliminary evaluation of engineering design considerations
construction considerations potential environmental impacts and scheduling
Figure 2 presents a graphic presentation of the existing Woods Pond and
Schweitzer Dam conditions
42 Description of Alternative
There are a number of methods available for modifying the existing
Schweitzer Dam to induce increased sediment deposition in Woods Pond and
inhibit resuspension and transport of the sediments to the downstream river
The improvements would also include measures to improve the stability of the
existing dam and optimize flow conditions through PCB-laden reaches of Woods
Pond Improvements to the dam andor approach channel would be designed
to most effectively reduce the impact of increased flood levels upstream of the
dam while assuring that water flow velocities through Woods Pond are
minimized Optimization of the flow conditions at the Schweitzer Dam could be
accomplished by implementing one or more of the following measures
- 13 shy
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
FIGURE 2
Woods Pond amp Schweitzer Dam Existing Conditions
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
1 Closure of the existing raceway channel
2 Lengthening and creating a multiple stage spillway or
3 Modifying the existing approach channel
These measures singularly or in combination would be designed to
optimize the flow conditions at the dam Each of these methods is described
below
Closure of the Existing Raceway Channel
The raceway adjacent to the Schweitzer Dam provides a means of low
level water release and reservoir drawdown with an associated potential for
increased water discharge velocities It is reported in the Stewart Report
all data obtained to data indicate that PCBs are in effect pulled from
Woods Pond and discharged from the by-pass canal into the Housatonic River
whenever the sluice gates are opened Therefore to minimize this potential
for sediment transport past the Schweitzer Dam the existing racewaybypass
system should be closed Closure of the raceway would preclude sediment
bed load transport assure that all releases from Woods Pond flow over the
spillway and assure relatively quiescent flow through Woods Pond For these
reasons each of the following flow and velocity control options incorporates
closure of the existing raceway channel
Lengthening and Creating a Multiple Stage Spillway
Lengthening and creating a multiple stage spillway on the existing dam
would involve the construction of an additional length of dam on the eastern
- 14shy
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
end of the existing dam (Figure 3) The spillway crest elevation on this
addition would be somewhat higher (possibly up to two feet) than the existing
spillway crest and therefore would only be spilling water during a storm
event that would result in increased water levels behind the dam During
such an event this portion would provide the additional spillway length
necessary to reduce the water approach velocities to the dam and therefore
provide increased sediment deposition during high flow events The
additional spillway length would also provide for an increased capacity with
which to convey increased flows associated with flooding events
Modifying the Existing Approach Channel
Modifying the existing approach channel would involve widening the
existing channel by removing the constriction formed by the existing
topography (Figure 4) This alternative increases the cross-sectional area
of the channel which will result in lower water velocities at any given flow
rate Modifying the channel would also help alleviate the turbulent and
varying velocities that are created by the contriction as it now exists and
would create a more uniform flow regime just upstream of the Schweitzer Dam
This option therefore will reduce the quantity of sediments that will be
resuspended just prior to discharge over the dam by providing more uniform
flow velocities in this area
43 Pre-Construction and Construction Activities
Pre-construction activities required to be performed for any of the flow
and velocity control alternatives in conjunction with or following design would
include the following
- 15shy
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
FIGURE 3
Woods Pond amp Schweitzer Dam Lengthen amp Create A Multiple Stage Spillway
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
FIGURE 4
Woods Pond amp Schweitzer Dam Approach Channel Modified
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
1 Submit documentation for and obtain all required permits
2 Obtain property rights-of-^ay from Kimberly-Clark (current dam
owners) for subsurface investigations design modification of the
Schweitzer Dam and temporarily lowering of the water level at
Schweitzer Dam (if necessary) and
3 Obtain all other property rights-of-way to access dam and
surrounding area
Construction activities would include the following
1 Construct staging area (for equipment and materials)
2 Construct a bypass system to divert river flow around the area
affected by the flow and velocity control alternative This bypass
system may consist of temporary use of the existing raceway
channel construction of a new bypass channel or the use of high
volume bypass pumps
3 Perform repairs on the existing dam structure to ensure continued
long-term safety and stability and
4 Implement flow and velocity control improvements which nay include
earth and rock excavation foundation preparation grouting and
concrete or riprap placement
44 Scheduling
It is estimated that the overall schedule for any of the flow and velocity
control alternatives would be two years The estimate is broken down into
the following components
- 16shy
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
1 Time to secure permitsfinal design 1 year
2 Construction of dam improvements 1 year
Total of 2 years
The estimated schedule presented above is optimistic Various delays
such as permitting delays may result in substantial time increases
45 Major Engineering Design Considerations
For each of the flow and velocity control alternatives described herein
additional laboratory testing and engineering would be needed to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Conduct safety and stability analyses of the dam and abutments
including determination of potential necessary repairs
2 Structural design of selected flow and velocity control option and
3 Development and design of a future reservoir drawdown system to
replace the existing raceway This will be necessary to provide
emergency water level drawdown capabilities necessary for
maintenance of the dam
- 17shy
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
46 Potential Environmental Impacts
Implementation of this remedial option would have no negative impacts on
the Housatonic River Valley Wildlife Management Area or any of the other
surrounding wetlands and river and will have no negative impacts upon the
local public or upon the availability of surface water and groundwater in the
area
Additionally the implementation of the flow and velocity control
alternative will have a positive impact during flood events by providing for
more uniform flow over the dam and by providing for increased capacity with
which to convey flow volumes associated with floods
- 18shy
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
River Channelization Alternative
ILASLANO amp BOUCK ENGINEERS PO
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
SECTION 5 - RIVER CHANNELIZATION ALTERNATIVE
51 General
This section will present the preliminary evaluation of the river
channelization alternative being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppn) The
objective of the river channelization alternative is to re-route portions of the
Housatonic River in such a manner that the PCB-laden sediments are isolated
from the river flow thereby eliminating the river water as a means of
sediment transport Presented within this section is a description of the
alternative as well as preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the river channelization alternative are presented within Section 2
of this Report
52 Description of Alternative
River channelization consists of creating a new channel in which the
existing river flow would bypass those portions of the Housatonic River
containing PCB-laden sediments The locations of the PCB-laden sediments
are presented in Figure 5 This new channel would be intended to connect
river segments with known non-PCB-laden sediments while bypassing those
segments with known PCB-laden sediments The proposed route of the new
channel is shown on Figure 6 The present river conditions and the river
conditions after completion of the proposed channel are shown in Figures 7
and 8 respectively
- 19 shy
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
SEWAGE FIGURE 5TREATMENT PLANT
A SAMPLE LESS THAN SO PPM OF PCS
bull SAMPLE HREATEft THAN SO PPM OF PCG
IOOO SOOO MOO FEET LOCATION OF PCB
CONCENTRATION VALLEY MILL 0AM
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
FIGURE 7
Conceptual View Of River Before
Channelization
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
The new channel would be designed to handle flows of a ten year storm
event based on potential flooding conditions defined by existing flood
insurance studies (Reference 6) A ten year storm event was selected
because it represents the generally accepted minimum level of protection for
engineering works of this type Preliminary indications are that a 150 foot
wide channel (at its base) vith a 12 foot depth would be required The
construction of such a channel would require excavation of approximately
500000 cubic yards of material Approximately 100000 cubic yards of this
excavated material would be utilized in the placement of the channel
embankment with the remaining 400000 cubic yards of unused excavated
material being disposed of Those excavated materials to be disposed of with
PCB concentrations greater than 50 ppm will be removed off-site and disposed
of in accordance with the US-Day Report while non-PCB-laden materials will
be spoiled (spread and graded) in the bypassed portions of the river and
backwater areas
In those areas where river channelization is not feasible the PCB-laden
sediments may require in-situ impoundment by either of the two options
outlined in Section 6 or removal and handling per the 45-Day Report
Figures 9 and 10 show an artists conception of the existing Woods Pond area
and the Woods Pond area with the proposed channel respectively
53 Pre-Construction and Construction Activities
Pre-construction activities required to be performed in conjunction with
the river channelization alternative include the following
- 20 shy
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
FIGURE 9
WOODS POND
PRESENT CONDITIONS Dravo V5raquon f-fouton
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
FIGURE 10
fj l (- TN r-v
C^1 -^ mdash^~v~xx
WOODS POND
WITH CHANNEL Orcivo
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981
55 Major Engineering Design and Considerations v j
^
For the river channelization alternative described above additional
laboratory testing and engineering would need to be conducted to verify the
assumptions made The following is a list of some of the additional major
engineering considerations that may be required
1 Development of a technique(s) to drain those areas being bypassed
by the proposed channel and consideration of the effects on the
upgradient and downgradient floodplain as a result
2 Determination of the acceptability of excavated soils as embankment
materials and
3 Determination of location of spoil or disposal areas for excess
excavated materials
U Evaluation of potential flood storage volume impacts and
5 Evaluation of potential groundwater and surface water impacts
56 Major Potential Environmental Impacts
The implementation of the river channelization alternative would result in
short-term and long-term effects upon the local environment These potential
environmental impacts are as follows
1 Wetland Destruction Alteration and Disturbance of Wildlife
Negative impact upon the existing ecological system by draining portions
of the Housatonic River Woods Pond and backwater areas This would
include the likely permanent destruction and significant alteration of
- 22 shy
3 Reduction of Flood Storage Volume
There will be a significant effect upon floodplains and a resultant
reduction of potential flood storage capabilities by performing
construction activities in areas above the normal existing water surface
of the river and backwater areas however flood waters wil l be
conveyed more expeditiously since many of the constrictions associated
with the meandering river course will be eliminated by the construction
of the proposed channel
4 Construction of Access Roads and Increased Traffic
Vehicular traffic and increased traffic disturbance on local roads
throughout the project duration including congestion increased
probability of accidents noise and deteriorated road conditions
5 Impact of Construction Activities on Local Public
Negative health and safety affects upon the local public due to the
potential health affects and nuisances which may result due to the noise
created by construction equipment and odors generated from exposure of
highly organic backwater areas during dewatering and re-routing
operations
The Housatonic River Wildlife Management Area would be greatly affected
by the construction of a new river channel within its boundaries The
draining of the backwater areas will significantly effect the current
conditions which are deemed essential for the Wildlife Management area
such as shallow marshy areas Therefore many recreational activities
such as canoeing fishing hunting and wildlife observation wil l be
significantly hindered
- 2H shy
In-situ Impoundment Alternative
UAampAND ft iOUCK ENOWEBW PC
SECTION 6 - IN-SITU IMPOUNDMENT ALTERNATIVE
61 General
This section will present the preliminary evaluation of the in-situ
impoundment alternatives being considered for segments of the Housatonic
River which contain PCB-laden sediments (greater than 50 ppm) The
objective of in-situ impoundment is to physically isolate the PCB-laden
sediments from contact with the flow of river water thereby eliminating the
river water as a means of sediment transport The in-situ impoundment
alternatives being considered are physical isolation (armoring) and chemical
stabilization Presented within this section is a description of each of the
alternatives as well as a preliminary evaluation of engineering design
considerations construction considerations potential environmental impacts
and scheduling The locations and general characteristics of the sediments
subject to the In-situ Impoundment Alternative are presented within Section 2
of this Report Figure 11 represents a conceptual cross section of the
existing river
62 Description of Alternative
Two options are being considered for the in-situ impoundment of the
PCB-laden sediments these being armoring and chemical stabilization These
options are described further below
Armoring - In this option the PCB-laden sediments would be impounded
in-situ by using a layer of inert material to physically isolate and
contain the sediments For sediments within the river channel the
- 25 shy
FIGURE 11
PCB-LADEN SEDIMENTS
I NOT TO SCALE I
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
TYPICAL CROSS SECTION
in-situ impoundment would be comprised of three layers each deposited
individually Approximately three to six inches of sand would be placed
above the sediments followed by four to six inches of crushed stone then
four to six inches of cobbles The heavy upper layers would protect
the sand and gravel against movement during periods of increased water
flow velocities In the backwater areas of the river and within Woods
Pond the in-situ impoundment would be comprised of only the sand and
gravel layer as velocities in these backwater areas would not be
sufficient to warrant the added protection cobbles provide Figure 12
presents a graphic presentation of this armoring alternative
The in-situ impoundment of the river sediments using the above
described method appears to be a practical approach to isolating and
impounding the sediments It may be efficiently implemented under
normal river flow conditions from a barge or other type of floating
platform however should the water depth be less than one to two feet
as is typical in much of the backwater areas placement of the armoring
materials cannot be completed by utilizing a barge or other floating-type
platform These shallower areas will require dewatering followed by
placement of the armoring materials by conventional construction
equipment Additionally the backwater sediments have been
characterized in the Stewart Report as fine sands to soft organic silts
and clays and may not have sufficient strength to provide a stable
subbase for the armoring materials Therefore it may be necessary to
further refine the placement procedure to include placement of a
geotextile fabric which will allow the release of water while confining the
sediments thereby providing a suitable subbase for the armoring
materials
- 26shy
FIGURE 12
COBBLES (IF NECESSARY) 4-6 PCB-LADEN SEDIMENTS
SAND (3-6-)
CRUSHED STONE (4-6)
I NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITE IMPOUNDMENT-ARMORING TYPICAL CROSS SECTION
Chemical Stabilization - In this option the PCB-laden sediments would be
impounded by stabilizing the upper layer of the sediments through the
use of additives The sediments to be stabilized using additives such
as fly ash cement or other proprietary chemicals must be excavated
mixed with the particular additive being used and then replaced to their
original position to harden or solidify This may be accomplished with
conventional construction equipment under dry conditions Therefore it
is only applicable to those backwater and river sediment areas which may
be dewatered and accessible to conventional construction equipment
There is one type of chemical stabilization that can be implemented
through the water column of a river or backwater area however this
method has been deemed inappropriate for a project of this magnitude
Figure 13 presents a graphic presentation of this chemical stabilization
alternative
63 Pre-Construction and Construction Activities
Pro-construction activities required to be performed in conjunction with
or following design would include the following
1 Submit documentation for and obtain all required permits and
2 Obtain property rights-of-way to access river
Construction activities would include the following
1 Construct temporary haul roads and staging areas (for armoring
materials or stabilization additives) and
- 27 shy
FIGURE 13
STABILIZED PCB-LADEN SEDIMENTS(ToP3)
(NOT TO SCALEI
GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS
HOUSATONIC RIVER STUDY
IN-SITU IMPOUNDMENT-CHEMICAL STABILIZATION TYPICAL CROSS SECTION
2 Place armoring materials by barge in undrained areas and by
conventional construction equipment in dewatered areas or place
stabilization additives by conventional construction techniques in all
areas (dewatered)
64 Scheduling
It is estimated that the overall schedule of the in-situ impoundment
alternatives would be four to five years This estimate is based upon the
sediment areas characteristics and locations described within Section 23
The estimate is broken down into the following components
1 Time to secure permittingfinal design 2 years
2 Construction activities 2-3 years
Total of 4-5 years
The estimated schedule presented above is optimistic Numerous delays
to the schedule may result in substantial time increases These tine
increases may be a result of permitting delays or weather-related delays
65 Major Engineering Design Considerations
For each of the in-situ impoundment alternatives described above
additional laboratory testing and engineering would need to be conducted to
verify the assumptions made The following is a list of some of the additional
major engineering considerations that may be required
- 28 shy
1 Determination of acceptable local sources of materials for armoring
2 Evaluation of the compatibility of various stabilization additives to
the sediments
3 Evaluation of groundwater flow and its possible impacts upon the
effectiveness of the in-situ impoundment alternative
4 Evaluation of bulking of sediments due to stabilization additives
and
5 Identification of the strength required and methods to obtain a
stable base for in-situ impoundment techniques
6 Development of an inspection program to evaluate and maintain the
effectiveness of in-situ impoundment techniques
66 Major Potential Environmental Impacts
The implementation of the in-situ impoundment alternatives would result
in short- and long-term effects upon the local environment The potential
environmental impacts are presented below
1 Sediment Resuspension
Negative environmental effects upon the river resulting from the
possibility of resuspension of sediments during the construction activities and
the potential impacts upon downstream water quality
2 Wetland Destruction Alteration and Disturbance of Wildlife
Negative effect on the local ecological system by the draining of many of
the backwater areas to allow for placement of the armoring materials or
- 29 shy
chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
- 30shy
5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
- 31 shy
Appfcation of Regulations BLASLAND ft BOUCK ENGINEERS PC
SECTION 7 - APPLICATION OF REGULATIONS
71 Introduction
A complex regulatory network will govern the implementation of the
channelization in-situ impoundment and flow and velocity control alternatives
addressed within this report Most of the identified Federal and State
regulations are pertinent to all of the alternatives therefore the following
discussion categorizes and defines these specific regulations according to their
appropriate Federal State or local jurisdiction If a regulation is not
applicable to all the alternatives presented within this report then the
exception will be detailed
Tables 1 and 2 (included at end of this section) present detailed outlines
of the applicable Federal and State regulations For each regulation the
following information is included
1 The Act under which the regulation(s) was promulgated
2 The relevant criteria or standards contained in the regulation
3 The permitting agency and its approval mechanism
4 The governmental agencies which have review authority
5 Submittals required for approval and
6 Ceneraf comments
- 32 shy
72 Federal Regulations
River amp Harbor Act and Clean Water Act
On the Federal level regulations promulgated under the River amp Harbor
Act and the Clean Water Act work together to regulate work in or discharges
of dredged or fill materials into navigable waters Specifically the
regulations require that a 404 Permit be obtained prior to the implementation
of any one or more of the alternatives addressed in this report
Under the River amp Harbor Act two sets of regulations are pertinent to
the alternatives The regulation for Permits for Dams or Dikes (33 CFR 325)
will be applicable specifically to the flow and velocity control alternatives In
addition the regulations for Structures or Work in Navigable Waters (33 CFR
322) govern activities that alter or modify the course condition location or
capacity of a navigable water The channelization alternative will alter the
location and course of the Housatonic River the in-situ impoundment
alternative will alter the condition of the river and the flow and velocity
control alternative will alter the capacity of the Housatonic River Therefore
these regulations will govern the implementation of all the alternatives
previously addressed Under the Clean Water Act the Regulations for Work
In Or Discharges of Dredged or Fill Material into Navigable Waters (33 CFR
322 323) will be applicable
According to the above regulations an application for a 404 Permit is
submitted to the Corps of Engineers which has permitting authority In
addition the EPA US Fish amp Wildlife and the Department of Marine
Fisheries have review authority An Order of Conditions issued by the local
- 33shy
greater than 50 ppm PCBs nust be handled in accordance with the technical
standards or upon application by an alternate disposal method approved by
the Regional EPA Administrator by means of a vaiver As stated the
alternatives addressed within this report will contain or confine the PCB-laden
sediments in-situ Therefore a TSCA waiver by the Regional Administrator
will be required for all of the stated alternatives
Hazardous Materials Transport Act
The vehicular requirements for the transport of PCB-laden sediments are
set forth in the Department of Transportation (DOT) Transport of Hazardous
Waste and Substance Regulations promulgated under the Hazardous Materials
Transport Act These requirements may be applicable to the flow and
velocity control and channelization alternative since these remedial actions may
require the dredging and off-site spoil or disposal of PCB-laden sediments
from the work areas
73 State Regulations
Wetlands Protection Act
The Regulations for Wetlands promulgated under the Wetlands Protection
Act will regulate all work which dredges fills or alters the land under
waterways banks or bordering vegetated wetlands andor changes the flood
storage hydraulics or capacity of a waterway Proposed activities must
achieve specific performance standards as set forth in the regulations A
- 35 shy
implementation of any of the alternatives wil l require the filing of an
application to the DEQE Division of Wetlands and Waterways under the
Waterways Licenses Regulations After an optional public hearing a permit
or license depending upon the type of work to be performed may be issued
Massachusetts Environmental Policy Act
According to the Massachusetts Environmental Policy Act an
Environmental Notification Form (ENF) and Environmental Impact Report (E IR)
will be required for each alternative addressed within this report
The ENF is required when a proposed project will alter greater than 500
feet of waterway bank (channelization and in-situ impoundment alternatives)
or structurally alter a dam such that there is a greater than 20 percent
increase or decrease of impoundment capacity (flow and velocity control
alternative) The EIR is required when a project relocates or channels
greater than 2000 feet of a navigable waterway (channelization alternative)
andor alters greater than 10 acres of wetland (channelization in-situ
impoundment and possibly flow and velocity control alternatives) The MEPA
Regulatory Unit has approval authority while numerous State and local
agencies have review authority
Massachusetts Hazardous Waste Management Act
The Massachusetts Hazardous Waste Regulations defer to the TSCA
regulations provided that either a TSCA approved incinerator or chemical
waste landfill is the method of disposal As stated previously Regional EPA
Administrator approval of an alternate disposal method will be required for all
- 37shy
of the proposed alternatives Therefore as stated in the Massachusetts
Hazardous Waste Regulations DEQE will retain approval authority over the
alternate disposal method to be implemented
Mills Dams and Reservoirs Act
Under the Dan Safety Program activities which involve changes to or
elimination of a dam in a Massachusetts waterway may require a permit if
that dam meets any of the following criteria potential downstream risk of life
or property from dam failure drainage area upstream in excess of 1 square
mile height of dam greater than 10 feet above river bed at any point
upstream or quantity of water impounded greater than 1 million gallons The
Department of Environmental Managements (DEM) Division of Planning and
Development is the permitting authority for the Dam Safety Program At the
present time there are no regulations however department policy governs
permitting for this program Regulations are currently being promulgated
under the Massachusetts Mills Dams and Reservoirs Act
Massachusetts Clean Air Act
Any PCB volatilization which may occur from the implementation of this
project will be regulated by the State Air Pollution Control Regulations
promulgated under the Massachusetts Clean Air Act There are general
regulations which prohibit fugitive air emissions of contaminants which may
cause air pollution and are administered by the DEQE Division of Air
Pollution Control
- 38shy
Major Non-Applicable Regulations
It has been determined that certain major Federal and State statutes are
not applicable to the implementation of the channelization impoundment and
flow and velocity control alternatives
The Resource Conservation and Recovery Act (RCRA) defers to TSCA
for PCB technical and regulatory requirements Therefore the regulations
promulgated under RCRA will not apply to remedial actions in the Housatonic
River
The regulations under the Federal Clean Air Act are applicable only to
criteria for ambient air pollutants and specific hazardous air pollutants of
which PCBs are not included
74 Local RegulationsRequirements
In addition to the Federal and State requirements specified above
numerous local regulations policies and guidelines will be identified and
complied with as appropriate
Once one or more alternatives have been designated for a more detailed
engineering evaluation these local requirements will be further defined
however Table 3 (see end of section) provides a listing of all the local
regulatory agencies which may be involved depending upon the locations
affected by the remedial actions
- 39 shy
75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and velocity control alternatives only
2 Hazardous Materials Transport Act Regulations for the transport of
Hazardous Wastes and Substances May be applicable to
channelization and flow and velocity control alternatives
3 Mills Dams amp Reservoirs Act Regulations currently under
promulgation Applicable to flow and velocity control alternatives
only
In summary the following acts will be applicable to the implementation of
channelization in-situ impoundment and flow and velocity control alternatives
Federal
1 River amp Harbor Act
2 Clean Water Act
3 Toxic Substances Control Act
4 Hazardous Materials Transport Act
1
2
3
4
5
6
7
State
Massachusetts Wetlands Protection Act
Waterways Act
Massachusetts Environmental Policy Act
Massachusetts Clean Water Act
Massachusetts Hazardous Waste Management Act
Mills Dams 6 Reservoirs Act
Massachusetts Clean Air Act
- 41 shy
RELEVANT AGENCY CRITICAL APPOVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY SUBMITTAL COMMENTS
River Act
t Harbor Permits for Dami or Oikoi 33 CFR 321
COE404 Permit EPA US Fish t Wildlife Dept of Marine Fisheries
Application -Only applicable for ltJm Improvement alternttivts
-Technical standards for 404 Permit 40 CFR 730
Structures or work In NavlgaMe Naurs U CFR 322
-Activities that alter or modify the course condition location or capacity of navlgablo waterway
COE404 Permit EPA US Fish I Wildlife Dept of Marine Fisheries
Application -Technical standards for 404 Permit 40 CFR 230
CWA Permit far Work In or -Discharge of fill COE404 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Maurial into NavigaMe Waters 33 CFR 122 323
material US Fish l Wildlife Dept of Marine Fisheries
-Technical standards for 404 Permit 40 CFR J30
TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBi
-Disposal of PCa-laden sediments
EPAApproval DEQE (if alternate disposal method requested)
Request forapprovalwaiver
-Approval of Regional Administrator
-TSCA definition of disposal
40 CFR 7i1M
Hazardous Materials Transportation Act
Transport of Hazardous Wastes ( Substances 4 CFR 172 laquo CFR 173SIO
-Vehicular requirements far transport of PCBi
DOTRogs EPA DEQE
-Only applicable to djni Improvement and chcnnel zatlon alternatives if removal of PCB-laden sediments required
TABLE
STATE
RELEVANT AGENCY CRITICAL APPROVAL REVIEW
ACT REGULATIONS INTERESTS MECHANISM AUTHORITY IUBMITTAL COMMENTS
Roguisuon tor bullotlenai lit CM It at
-Alter lend under bullotai-Mys banks
-Change flood Morage hydraulicscapacity
Local Conservation CoMMulons Order of
DCQE Notice of Intent
tundardi hwrlng (Mandatary )
-Applaquol u OEOE -Ordar ef Candltiant
-Altar bordering vegetated wetlands
Conditions -Raqutrad priorof M Parvit
to lasuanca
MCWA Cert DredgingDredge etaterlel Oiinaill I nil In
-CoBpllenca with all water quality regulations
OEOE (wPCI Certification
Application -Public hoaring (Nono) -Roquirod prior to Iftsuanca
11 Qtt M
oyraquo 11 CMM IM
-bullark wMch occuri In
been tna recipient of public bullanoy tor
DEQE (Oiv or bullatlartdt t bullatanuy) Pami t
Application -Public hearing (Optional)
MEM Ml raquoA IMF AutomalK MCPA Umi Stata Local ENF and EIR Ml CM IfN
-OUpaill gtIIM cy W avtarbl
-Structural altoratloni a don raquogtIH inc or
IIR AUUMMJC Hraeraquo relocation or
chonnelUeUon of
-Alter Mt acres of wetland subtact to c111 sat
Hazardous bullotto
II i 11 i m lt
M17 MM1
MW1
-PClaquo disposal i
-Tirnniport i ovnltat
OEQEApproval -Stato rofori to TSCA -Altornoto dlipoul
MMJor TSCA OEOE
MilU t
Currant uodor -Utah of Mlaquolaquo or OEM Application -Only applicable to dam nt altomotlvoi
Act
MCAA Air relejllen Control Rogulobonii am 7M
-Pugitlvo air DCOE IDIv of Air Pollution Control IRogi
-Conoral rogulaUom lor any aourco of air pollution
TABLE 3
LOCAL REGULATORY AGENCIES
a) Local Boards (General)
(1) Selectmen (2) Planning Board (3) Sewer Commission (4) Board of Health (5) Conservation Commission (6) Historical Commission (7) Department of Public Works (8) Hazardous Waste Coordinators (9) Local Utilities
b) Pittsfield
(1) Floodplain Bylaw (2) Earth Removal Bylaw (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
c) Lenox
(1) Floodplain Bylaw (2) Earth Removal Bylaw - Permit Public Hearing (3) Performance Standards (4) Landscaping Requirements (5) Screening Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
d) Lee
(1) Floodplain Bylaw (2) Stream and Pond Protection (3) Earth Removal Bylaw (4) Performance Standards (5) Landscaping Requirements (6) Wetlands Protection Act (See State Regulations) (7) Building Permit
e) Other Interested Parties
- Berkshire Regional Planning Authority - Berkshire Natural Resources Council (Berkshire Land Trust) - Audubon Society - Conrail - Berkshire Community College - Industrial water users abutting river - Agricultural water users abutting river - Commercial enterprises using river
ACT
FEDERAL
River pound Harbor Act
CWA
TSCA
Hazardous Materials Transshyport Act
STATE
WPA
MCWA
Waterways Act
MEPA
Hazardous Waste Management Act
Mills Dams pound Reservoirs Act
MCAA
TABLE 4
SUMMARY TABLE
REGULATIONS
Permits for Dams or Dikes 33 CFR 321
Structures or Work in Navigable Waters 33 CFR 322
Permit for Work in or Discharges of Dredged or Fill Materials Into Navigable Waters 33 CFR 322 323
Disposal of Dredged Material pound Municipal Sludge Containing PCBs 40 CFR 76160
Transport of Hazardous Wastes pound Substances laquo9 CFR 172 laquo9 CFR 173510
Regulations for Wetlands 310 CMR ia00
Cert Dredging Dredged Material Disposal pound Fill in Waters 31laquo CMR 900
Administration of Waterways Licenses 310 CMR 900
MEPA Regulations 301 CMR 1000
Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801
Currently under Promulgation
Air Pollution Control Regulations 310 CMR 700
CHANNELIZATION
X
X
X
X
X
X
X
X
X
-
X
IN-SITU IMPOUNDMENT
X
X
X
-
X
X
X
X
X
-
X
DAM IMPROVEMENTS
X
X
X
X
X
X
X
X
X
X
X
X
Summary IIAampAND ft IOUCK momsRs PO
SECTION 8 - SUMMARY AND RECOMMENDATIONS
8 1 Summary and Recommendations
This 90-Day Interim Report provides the first step in evaluating the
remedial alternatives of Flow and Velocity Control River Channelization and
In-situ Impoundment In addition this Interim Report identifies the major
engineering and potential environmental considerations of eacn of these
alternatives as well as the applicable regulatory requirements and
implementation schedules
The next step will be to develop and evaluate the potential environmental
impacts associated with the three alternatives described in this Interim Report
and to enable further screening utilizing the NCR criteria This evaluation of
the environmental impacts will be completed and submitted in the 135-Day
Interim Report In addition the 135-Day Interim Report will provide further
screening of the alternatives described in the US-Day and 90-Day Interim
Reports based upon their engineering feasibility During the time period
between the 90-Day Interim Report and preparation of the 135-Day Interim
Report it is recommended that the local public be made aware of the
information provided in this report to determine public acceptability of the
three described remedial alternatives
The 135-Day Interim Report will include additional assessment of public
concerns environmental impacts and engineering considerations associated
with all of the alternatives presented in both the 45-Day and 90-Day Interim
Reports
- 42shy
Upon Regulatory Agency acceptance of the recommendations of the
135-Day Interim Report work wi l l commence to provide a detailed evaluation
of the selected remedial option(s)
Respectfully submitted
BLASLAND S BOUCK ENGINEERS PC
William H Bouck PE
Vice President
Prepared by
Blasland amp Bouck Engineers PC Robert K GoldmanPE Dawn M Sheldon
Erseco Inc Roberta J Fine Ruth Geoffrey Robert Bouchard
OBrien amp Gere Engineers Inc Andrew N Johnson PE George C Elias PE
Dravo Van Houten Phillip Sears
References BLASLAND amp BOUCK ENGINEERS PC
REFERENCES
1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by Blasland amp Bouck Engineers PC dated October 1984
2 Stewart Laboratories Inc December 1982 Housatonic River Study - 1980 and 1982 Investigations Volume I and II prepared for General Electric Company
3 Erseco Report Proposed Engineering Evaluation of the Selected Housatonic Remedial Alternatives May 1984
4 Source Control Feasibility Study OMC Hazardous Waste Site Waukegan Illinois EPA 13-5M 280 W6532800 7 1483
5 NUS Corporation Executive Summary Draft Feasibility Study of Remedial Action Alternatives Acusnnet River Estuary above Coggeshall St Bridge New Bedford Site NUS Project No 072516 August 1984
6 Federal Emergency Management Agency Flood Insurance Studies Town of Lenox January 1982 and Flood Insurance Studies Town of Lee December 1981