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FfAL o- RCRA RECORDS CENTER FACU ITY d I.D. NO./ A. v FILE LOG. OTHER REPORT BLASLANO A BOUCK ENGINEERS, P.O. 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
Transcript
Page 1: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 2: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 3: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 4: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 5: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 6: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 7: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 8: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 9: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 10: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 11: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 12: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 13: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 14: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 15: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 16: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

- 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

Page 17: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 18: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

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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

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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

- 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

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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

Page 19: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 20: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 21: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 22: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 23: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 24: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 25: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 26: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 27: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 28: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 29: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 30: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 31: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 32: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 33: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 34: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 35: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 36: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 37: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 38: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

Page 39: HOUSATONIC RIVER STUDY, 90-DAY INTERIM REPORT, … · 2020. 8. 21. · The nex report preparedt th 135-Dae, Interiy Reportm , will th presene t further evaluatio of alnl remedia the

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

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