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Rest of River Draft Permit Modification Public Hearing 9/23/2014

413.732.1157 [email protected] 508.767.1157Springfield REAL TIME COURT REPORTING Worcester

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Pages 1-73

________________________________________________

ENVIRONMENTAL PROTECTION AGENCY

RE: REST OF RIVER

DRAFT PERMIT MODIFICATION

________________________________________________

PUBLIC HEARING FOR

REST OF THE RIVER

DRAFT PERMIT MODIFICATION

HELD SEPTEMBER 23, 2014 AT THE

LENOX MEMORIAL MIDDLE AND HIGH SCHOOL

197 EAST STREET

LENOX, MASSACHUSETTS

Reporter: Raymond F. Catuogno, Jr.

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1 SPEAKERS: PAGE

2 Mr. Cianciarulo ............................ 3

3 Mr. deFur .................................. 7

4 Mr. Larson ................................. 12

5 Ms. Cushing ................................ 14

6 Ms. Andersen ............................... 19

7 Mr. Regan .................................. 22

8 Mr. Cook ................................... 26

9 Mr. Federer ................................ 32

10 Ms. Cianfarini ............................. 32

11 Mr. Gray ................................... 38

12 Mr. Friedman ............................... 42

13 Mr. Cianfarini ............................. 45

14 Mr. Kronberg ............................... 47

15 Mr. Berkel ................................. 50

16 Mr. Alsop .................................. 51

17 Mr. deFur .................................. 55

18 Ms. Barzottini ............................. 57

19 Ms. Miller ................................. 58

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21

22

23

24





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1 1 MR. CIANCIARULO: Good

2 2 evening. My name is Bob Cianciarulo and

3 3 I'm from the EPA Region One office in

4 4 Boston. We're here tonight for the public

5 5 hearing regarding the Draft Modification

6 6 to the reissue RCRA Permit for the General

7 7 Electric Company facility in Pittsfield,

8 8 Massachusetts. I will be the presiding

9 9 officer for this hearing. This hearing is

10 10 now come to order.

11 11 RCRA or the Resource

12 12 Conservation Recovery Act is a federal law

13 13 addressing hazardous and solid waste. In

14 14 1991, EPA issued GE a permit for

15 15 corrective action regarding releases of

16 16 hazardous waste, including PCBs, at the

17 17 GE's Pittsfield facility. That corrective

18 18 action permit has been modified or reissue

19 19 several times since 1994. The reissue

20 20 corrective permit is part of a larger

21 21 Consent Decree under which GE is required,

22 22 among other things, to complete

23 23 investigation and remediation of different

24 24 areas of contamination in Pittsfield and





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1 1 three segments of the Housatonic River.

2 2 The hearing tonight is with

3 3 respect to the Rest of River segment of

4 4 the Housatonic River. This Rest of River

5 5 is from a confluence of the east and west

6 6 branches of the river in Pittsfield just

7 7 below Fred Garner Park flowing through

8 8 Massachusetts and Connecticut for roughly

9 9 125 miles. Under the decrees and the

10 10 reissue RCRA permit, GE is required to

11 11 perform certain investigation and analysis

12 12 of the Rest of River based on the

13 13 administrative record filed, which

14 14 includes the information submitted by GE

15 15 as well as other information EPA has

16 16 proposed, to remedial action for the Rest

17 17 of River. That proposal is in the Draft

18 18 Permit Modification and Statement of Basis

19 19 issued in June 2014.

20 20 EPA held information sessions

21 21 here in Lenox on June 18, 2014 and in

22 22 Kent, Connecticut on June 24, 2014. The

23 23 formal public comment period for the Draft

24 24 Permit Modification began on June 25, 2014





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1 and is scheduled to end on October 27,

2 2014. Following the closure of the

3 comment period, EPA will review and

4 consider all comments received during the

5 public comment period both in writing and

6 provided verbally at this hearing.

7 Under the decree, the next

8 steps are as follows: EPA is to notify GE

9 of EPA's intended final decision on the

10 Permit Modification, after which GE has

11 the opportunity to dispute EPA's intended

12 final decision. After completion of the

13 dispute resolution period, or GE does not

14 invoke dispute resolution after thirty

15 days from EPA's notification to GE, EPA is

16 to issue a final modification of the

17 reissue RCRA permit. That final permit,

18 unless appealed, will obligate GE to

19 perform the EPA-selected cleanup.

20 At this hearing, any person

21 may submit oral or written statements and

22 data concerning the Draft Permit

23 Modification. EPA will not be responding

24 formally tonight to oral or written





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1 statements. When EPA issues a final

2 permit modification decision, EPA will

3 issue a response to comments. The hearing

4 is being transcribed by EPA to make ensure

5 that all comments are received and the

6 hearing is being taped and recorded. And

7 in addition to making comments today, you

8 may also provide written comments to the

9 EPA during the public comment period.

10 To help make this hearing run

11 smoothly, I ask anyone who would like to

12 make a statement come to the microphone

13 set up on either side of the stage here.

14 Before you begin your statement, please

15 identify yourself and for the aid of our

16 stenographer, spell your name, and provide

17 your affiliation for the record. There

18 are a lot of people here tonight. To

19 ensure that everyone has an opportunity to

20 express their views, I ask that you limit

21 your comments to five minutes. At any

22 time, if you're asked to stop, but you

23 have not completed your comments, I will

24 ask that you defer the remainder of your





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1 comments until each person has had an

2 initial opportunity to comment. If there

3 is time at the end of the evening, we'll

4 give you an opportunity to finish those

5 comments. If you have a written

6 statement, you may read it, if it can be

7 done in five minutes. If not, I would ask

8 you to summarize those comments and submit

9 that written comments for the record. In

10 either case, I encourage you to submit a

11 written statement tonight or before the

12 close -- of the end of the close of the

13 public comment period. With that, I

14 invite anyone wishing to make a comment to

15 step to the microphones.

16 MR. deFUR: My name is Peter

17 deFur. I don't think it's coming across.

18 I live in Richmond, Virginia. D-E,

19 capital F-U-R. I'm a consultant at

20 Environmental Stewardship Concepts. I

21 work under a technical assistant grant

22 from EPA to the Housatonic River

23 Initiative for whom I work. I'm here to

24 provide comments on the Draft Permit and





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1 Basis.

2 Basically, they are inadequate

3 to protect the public health and the

4 environmental ecological receptors. They

5 do not remove enough of the PCB mass or

6 the contaminated sediment from the river,

7 the river system, the floodplains, vernal

8 pools, or any of the associated areas.

9 The result is that for the foreseeable

10 future, if not in perpetuity, the region

11 will be contaminated with PCBs. The

12 problem will be that low level PCBs will

13 continue to poison wildlife, they will

14 continue to poison the river, they will

15 continue to be transported down river,

16 accumulate in sediment and accumulate in

17 wildlife.

18 We know from extensive

19 research on human health and ecological

20 systems that PCBs are incredibly toxic at

21 low levels. Every year we learn new

22 dangers from PCBs. Just last year the

23 World Health Organization determined that

24 PCBs are a known human carcinogen.





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1 Continued research in the peer review

2 literature indicates that community

3 members surrounding PCB-contaminated sites

4 have elevated concentrations of PCBs in

5 their bodies. The entire community around

6 the Housatonic River is likely exposed to

7 PCBs at levels that are causing biological

8 responses, including depressed immune

9 systems, learning disabilities in

10 children, and abnormal development of the

11 fetus.

12 Wildlife studies come out anew

13 every month indicating that low levels of

14 PCBs interfere not only with fish

15 reproduction, amphibian reproduction, bird

16 reproduction, but also with bird behavior

17 and bird songs. And that these are not

18 limited to birds. That the soil

19 invertebrates, the insects, the worms, and

20 the minute crustaceans that live not only

21 in the river, but also in the soils, are

22 subject to these same adverse effects.

23 All of these combine to make it more

24 imperative that the Draft Permit and Basis





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1 be modified to remove a much greater mass

2 of PCBs from the system.

3 One of the consequences is

4 going to be if the permit is implemented

5 as written, that there will be a great

6 amount of hardscape, that is fixed channel

7 river. That fixed channel river is simply

8 not practical under the current scenario

9 of weather changes and the known increase

10 in severe weather that is going to occur

11 in this system as well as others. We have

12 already seen it, and it's only going to

13 get worse. Which means that the river's

14 normal meander is going to meander even

15 more in the coming years, which will make

16 any hard fix, any hard remediation, such

17 as bunkering and riprap, it is going to be

18 impermanent even if we think it is going

19 to be permanent.

20 Ecology and restoration

21 methods have advanced manyfold in the last

22 ten or fifteen years. The Housatonic

23 River in this region is ripe for using the

24 newest techniques for restoration. It is





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1 also ripe for using the most recent modern

2 methods in remediation, that is for

3 removal. Not large scale, bulk, steam

4 shovel type of removal of sediments, but

5 pinpointed hydraulic removal with piping

6 down to centrally located processing

7 areas, where in some cases we can even

8 pilot new modern techniques for PCB

9 detoxification, dechlorination, and

10 elimination.

11 In closing I want to point out

12 also that other sites are using plant

13 banks to extract the plants that are in

14 place that need to be remediated and

15 culturing those elsewhere for use when the

16 restoration occurs. We recognize that

17 what is going to happen here if this plan

18 is implemented as written, is that humans

19 will continue to be exposed at excess

20 levels, wildlife will continue to be

21 exposed at excess levels, all sorts of

22 invertebrates and even microbes will be

23 exposed at levels that are known to cause

24 effects. Nobody knows how those effects





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1 alter the entire ecosystem.

2 I will be submitting written

3 comments for the record on behalf of HRI.

4 Thank you very much for your time and

5 attention.

6 MR. CIANCIARULO: Thank you.

7 MR. LARSON: My name is Joseph

8 Larson, L-A-R-S-O-N. I'm an emeritus

9 professor of environmental conservation at

10 the University of Massachusetts, Amherst.

11 Tonight I would be speaking for the

12 Massachusetts Fisheries and Wildlife board

13 of which I'm a member.

14 The Division of Fisheries and

15 Wildlife, which is supervised by our board

16 is the largest landowner in the affected

17 area of the Housatonic. The land and

18 wetlands in our care were acquired by gift

19 or purchase from donors and funds, where

20 the expectation, backed by our pledge, is

21 that these areas would be preserved in

22 perpetuity for their natural and

23 recreational values. They are officially

24 recognized by the state and other





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1 authorities for its unique and rich

2 natural resources. It is also an area

3 that is highly valued for outdoor

4 recreation by residents of Massachusetts.

5 It annually attracts people from across

6 the state and from other states in the

7 nation.

8 Our board recognizes that the

9 PCB contamination poses a public health

10 risk that must be addressed. We have

11 provided extensive assistance to the EPA

12 in the form of division staff time, field

13 studies, and scientific analysis. We are

14 also aware that there is no silver bullet

15 solution that applies to every area that

16 is contaminated with PCBs. Each area in

17 the nation where PCB contamination exists

18 has required development of a unique

19 approach that cannot be simply copied for

20 any other contaminated area.

21 This plan, including mass

22 removal of PCBs from Woods Pond, presented

23 by EPA, has been crafted to responsibly

24 address public health risks while at the





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1 same time responsibly maintaining as much

2 as possible of the natural and

3 recreational values of this section of the

4 Housatonic. It's been a difficult

5 balancing act, but it is a Housatonic

6 plan, and it has our full support.


8 MS. CUSHING: My name is Becky

9 Cushing, C-U-S-H-I-N-G. I'm the sanctuary

10 director for Mass Audubon's Berkshire Wild

11 Life Sanctuaries.

12 Mass Audubon has been closely

13 engaged in the planning process for the

14 cleanup of PCBs for the Housatonic River

15 for many years. The following comments

16 are preliminary and provide an overview of

17 key points from our perspective. We will

18 be developing more detailed written

19 comments during the extended comment

20 period, and we appreciate the additional

21 time provided for comment.

22 This remediation planning

23 process has taken decades, and the cleanup

24 is projected to take more than another





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1 decade to complete, once approved. This

2 is unfortunate, yet not unexpected, as

3 remediation of such extensive

4 contamination of the environment with

5 persistent, insidious toxic substances

6 must proceed with appropriate care and

7 deliberation. It is also vitally

8 important that the remediation plans

9 provide the opportunity to learn from

10 experience as cleanup phases proceed,

11 include flexibility to incorporate

12 improved science and methods as they

13 become available, and address the

14 inherently dynamic nature of river

15 systems.

16 Mass Audubon is both a

17 directly impacted landowner at our Canoe

18 Meadows Wildlife Sanctuary, and has a

19 broader interest in the conservation and

20 restoration of the Housatonic River

21 ecosystem for the benefit of both people

22 and wildlife Our property is located at

23 the head of the Rest of the River, where

24 the methods for the cleanup will first be





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1 applied, and this property contains

2 habitat for numerous rare and common

3 species of plants and animals.

4 We are encouraged in several

5 respects by the Statement of Basis and

6 Draft Permit in that they explicitly

7 address several of our previous key

8 comments. Notably, the concepts of

9 project phasing and adaptive management

10 have been incorporated. The conceptual

11 cleanup plan also recognizes the

12 sensitivity of the natural ecosystems

13 located within the project area, and calls

14 for higher levels of protection for some

15 of the most sensitive features, such as

16 endangered plants.

17 Despite this progress,

18 however, the documents fall short of

19 providing a clear plan for the proposed

20 work, nor do they address critically

21 important factors that will affect the

22 integrity and effectiveness of the

23 remediation over the long term. Riverine

24 systems such as the Housatonic are





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1 inherently unstable and dynamic. The

2 documents attribute much of the

3 instability of current eroding banks to

4 historic land uses that disrupted flow

5 regimes, and predicts that the system will

6 reach dynamic equilibrium in the near

7 future. This ignores the fact that rivers

8 by their very nature move and shift in the

9 landscape over time, and that climate

10 change is leading to more intense and

11 extreme storm events that increase the

12 likelihood of catastrophic floods.

13 Leaving significant amount of PCBs within

14 floodplains in the most ecologically

15 sensitive areas may be appropriate for the

16 short term as a first phase of cleanup.

17 It is not, however, wise in the long term

18 context given the persistence and toxicity

19 of these chemicals. The plans should be

20 revised to provide for future additional

21 remediation, incorporating more extensive

22 application of adaptive management

23 principles and development of more refined

24 ecological restoration methods. The final





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1 plan also needs to include plans for

2 response to extreme catastrophic flood

3 events that disrupt large areas of river

4 bank, bottom sediments, and floodplain.

5 This Statement of Basis and

6 Draft Permit do not, in fact, constitute a

7 comprehensive cleanup plan. Rather they

8 outline a conceptual approach. Additional

9 information is required as stated in the

10 Draft Permit, including further sampling;

11 as well the work plan, schedule, and

12 sequencing of work; access points;

13 material and equipment stockpiling

14 locations and haul roads; community health

15 and safety plan; restoration plan;

16 adaptive management plan; dam operation

17 and maintenance plan; invasive species

18 control plan, institutional control plan;

19 and plan for further response actions.

20 The draft permit calls for General

21 Electric to submit all of these documents

22 to EPA for review and approval, but there

23 is no formal opportunity for effected

24 landowners or the public to review and





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1 comment on these vitally important details

2 before they are finalized and implemented.

3 Mass Audubon calls on GE and EPA to

4 provide for further opportunity for input,

5 particularly from effected landowners, the

6 surrounding and downstream communities,

7 and other stakeholders, such as people who

8 have an interest in recreational uses of

9 the river.

10 Thank you for considering

11 these comments.

12 MS. ANDERSEN: Good evening, I

13 am Valerie Andersen, A-N-D-E-R-S-E-N. I

14 live in Pittsfield. I favor a robust

15 cleanup of the Housatonic River. The EPA

16 plan is good in some respects. The phased

17 plan I think is good in that no one town

18 will have the work done for the whole

19 project time. For example, in Pittsfield,

20 the work would only take five years, which

21 is less than the amount of time it took to

22 remediate the first three miles in

23 Pittsfield. So it would be cleaned up

24 within a five-year time period in





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1 Pittsfield. Another good thing about the

2 plan is that it does call for some

3 adaptive technologies.

4 However, where the plan falls

5 short is that it would leave what is known

6 as core areas contaminated up to 49 parts

7 per million. Now, people probably don't

8 realize it, but if there is 50 parts per

9 million, that is the highest level toxic

10 landfill standard, called the TSCA

11 landfill. Fifty parts per million is a

12 TSCA landfill, a toxic waste dump. And

13 your plan is allowing up to 49 parts per

14 million. So just one little part per

15 million less. So in effect, it's like the

16 plan is allowing all these little toxic

17 waste dumps in the core areas to be left

18 there. And the rationale is for a guise

19 of sustaining habitats. But it makes no

20 sense to sustain a polluted habitat. So

21 we're going to have all of these little

22 toxic waste dumps left there, up to 49

23 parts per million, when 50 would be a

24 highly regulated toxic landfill.





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1 There's many of us in this

2 community who have been affected by cancer

3 in our families, rare blood disease,

4 multiple sclerosis. PCBs are really toxic

5 poisons that should be cleaned up, and we

6 should not let there be pockets of little

7 toxic landfills in the Rest of the River.

8 We have a responsible party,

9 General Electric, one of the richest

10 corporations in the world who has the

11 resources to do a cleanup of this area.

12 We should do it now; we should not wait.

13 We should not do a half-baked cleanup

14 right now, because in the future, you

15 might have to come back. And those people

16 who worry about disrupting neighborhoods

17 and tourist attractions and things like

18 that, it's not going to be any good for

19 the tourists or the neighbors if we have

20 to come back and do it all over again.

21 So in conclusion, I do favor a

22 robust cleanup. I think that the plan

23 proposed does not go far enough,

24 especially allowing 49 parts per million





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1 to be left in the river. Thank you.


3 MR. REGAN: My name is Dennis

4 Regan, R-E-G-A-N, and I represent the

5 Housatonic Valley Association. And I

6 don't think I need to spell Housatonic. I

7 would like to thank you as well for the

8 opportunity to provide comments on the

9 draft remediation plan. However, we would

10 like to state that we feel that the

11 current proposal does not go far enough to

12 protect the health of the river, of

13 wildlife, and of human health. The

14 proposal leaves behind 75 percent of the

15 PCBs, which to us does not seem like a

16 very good remediation plan. It leaves far

17 too many PCBs behind either -- behind in

18 either the floodplain, the river bottom,

19 or under the sand rug. HVA will submit a

20 written comment that goes into more detail

21 on these issues, but for right now for

22 this presentation I will just hit some of

23 the main areas or our main concerns.

24 Primarily, it's leaving the





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1 core habitat areas contaminated. These

2 areas of rare endangered species, we're

3 very fortunate we have so many in such a

4 unique area in the wildlife refuge, in

5 that area in the Rest of the River, but

6 they are contaminated. Their habitats are

7 contaminated. And they will stay

8 contaminated until we do something about

9 it. So logically, that not does not make

10 any sense at all to me.

11 EPA has also proven that they

12 can restore rare endangered species in

13 areas such as they did in the vernal pools

14 in Pittsfield, where they removed the

15 species, cleaned up the contaminated

16 sites, and replaced the species, and let

17 mother nature take its course. And that

18 has proven effective. And I think they

19 can do the same thing again here.

20 Another main concern we have

21 is the high degree of sand capping. And

22 again, we feel that capping is basically

23 sweeping the PCBs under a sand rug. It

24 may look good for now; we have serious





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1 doubts it could withstand the test of

2 time, especially in an active, dynamic

3 riverbed system. We feel that there is

4 too much reliance on the use of capping

5 and would rather see actual removal of the

6 contaminated soil.

7 Another area of concern is the

8 high parts per million that is considered

9 safe for our area. That is 49 or 50 parts

10 per million, which is being proposed in

11 that area. And when we just were going

12 through the PCB remediation in Pittsfield,

13 we had 2, 10, or 25 percents that were

14 considered so-called safe levels. Well,

15 now we're thinking 49 percent is safe. If

16 we had 49 percent up in Pittsfield, that

17 would have been considered a hot spot and

18 not a safe area. So there's some

19 irregularities there, I think.

20 However, there are some

21 positive points in the remediation plan as

22 it stands right now. We're very much in

23 favor of the no onsite landfills. We are

24 very much in favor of the sediment removal





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1 behind the dams. And we appreciate the

2 concern over the removal of the

3 contaminated soil, be it by -- the two

4 main areas via road or railway. And we

5 appreciate the railroad alternative,

6 although it's still going to need a lot of

7 discussions and negotiations and

8 technology, trying to figure out how to do

9 that best. And remedial technology

10 investigation, the ongoing investigation

11 that Susan so accurately placed on some

12 pixie dust that will solve the problem.

13 We're still hoping for that. And

14 continued monitoring is essential, and

15 we're very happy to see that that ia still

16 part of the plan.

17 But again, we feel that the

18 more contaminated soils need to be removed

19 from the river and floodplain. We have an

20 opportunity to remediate now and we should

21 take advantage of this opportunity rather

22 than lose it for all time. We do

23 understand the valid concerns regarding

24 the negative impacts related to this





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1 remediation process. We realize that

2 there will be a cost for restoring the

3 river. I wish we didn't have to dig up

4 the river and the floodplain, but since

5 PCBs cause serious harm to wildlife and

6 humans, we feel we need to remove this

7 threat. Therefore, we feel the short-term

8 disturbances are worth the long-term

9 security of a healthy environment for us

10 and future generations.

11 We unfortunately have a river

12 that qualifies as a Super Fund site. The

13 Environmental Protection Agency's job is

14 to protect the environment and human

15 health, and I know that you want to do the

16 right thing. So, please, this is the

17 opportunity to do so. Thank you.


19 MR. COOK: Good evening. I'm

20 Jeffrey Cook. I live at 9 Palomino Drive.

21 I'm one of the coordinators of a group

22 called Ward 4 River Watch, about 400

23 families that are located on both sides of

24 the river and very concerned about the





27

1 impact of the cleanup on our neighborhood.

2 We're also concerned about the impact of

3 the cleanup on the wildlife areas, and

4 once again, raise the question of how do

5 we get to these standards. I have heard

6 tonight about some additional scientific

7 information, which I think we ought to

8 have a standard that when people say those

9 things, they ought to submit the report,

10 because we have more than once had a

11 situation where the study itself says we

12 can't show causality, we can show

13 associations; there is a huge difference.

14 And then people come up to the mike and

15 say, this causes this and this causes

16 that.

17 Here's some things that the

18 Department of Public Health has

19 determined, that in the Allendale area,

20 the Allendale School, around the river,

21 blood tests have been made; there is no

22 elevated level of PCBs among the

23 population. There is no detectable levels

24 of PCBs in the air above the floodplains





28

1 and river. But we know that is going to

2 change. Because we're going to have

3 thirteen years of digging this up. And so

4 for some of these neighborhoods, we'll

5 have five years of this stuff in the air,

6 where right now it's not there.

7 I have to say that I have

8 participated in this process for years and

9 I basically lost confidence in the EPA

10 process. And it bothers me because I like

11 a lot of you. I think this is a very

12 cynical process. We're now having

13 hearings and comment periods on what the

14 cleanup is going to be. But of course,

15 we're leaving out things like access roads

16 and staging areas, which are going to have

17 a huge impact on the areas, the

18 floodplains, the river. And it makes a

19 huge difference.

20 If we had a vacuum cleaner in

21 the sky and we could suck out all the

22 PCBs, that would be cool, and that would

23 be great. But that is not what is going

24 to happen.





29

1 And when you say to us, oh,

2 look we're going to pump the PCBs down

3 river and don't mention that every cubic

4 yard that gets removed is going to be

5 replaced with clean fill, is that going to

6 be pumped up? So there are going to be

7 access roads and there are going to be

8 staging areas where the material is

9 dewatered and moved from one container to

10 another, where there is heavy equipment

11 stored that starts at 6:00 and 7:00 in the

12 morning. There are only so many places

13 that these things can be, and you know

14 that. And you know the likely places. So

15 when we raise the question, and you tell

16 us, no, we're not sure, it's very

17 disturbing. It's very disturbing.

18 Let's talk about rail. We're

19 talking about 10,000 truckloads a year,

20 four trucks an hour. Where is the rail

21 depot going to be to handle that material?

22 You make it sound as if the roads around

23 the neighborhoods and the river are not

24 going it be taxed, because somehow the





30

1 material gets to the rail. It's a monster

2 to have that kind of a rail operation.

3 Where is that going to be? We should be

4 comfortable though because we're going to

5 talk about rail.

6 The other thing that we talk

7 about is new techniques. There is no

8 likelihood that this stuff can be treated

9 today, what we know, and the levels we're

10 talking about in situ. We talked about it

11 and I have to compliment Tim Gray, because

12 I think he has worked harder than anybody,

13 on looking for alternatives. And he has

14 over the years named a few, and nothing

15 has come to the floor. So we can talk

16 about these things, but I think you know,

17 I think you, EPA, know that we're going to

18 have to excavate the river bank to bank

19 until we get down to New Lenox Road. You

20 know there is going to be access roads,

21 you know there is going to be staging

22 areas, and some of the alternatives that

23 are being suggested do not solve the

24 problem of putting back in a cubic yard of





31

1 material for every cubic yard of material

2 that is removed.

3 So this is all post-permit.

4 And that is where there is huge impact on

5 the environment and on the neighbors. So

6 we're going to hear that we had a process,

7 we had public hearings, we got input, and

8 we know that this is the remedy. Except

9 the remedy gets delivered a certain way

10 and that is not being discussed now.

11 So for those of us who look at

12 this in the neighborhoods, that will live

13 with this for five years, and say, what is

14 happening to us? And that is post-permit.

15 And what is going to happen to these

16 special Core 1 areas where the river bends

17 back, and you're somehow going to have the

18 equipment in there to excavate the river

19 bank to bank, but yet in the core areas

20 you're going to be able to do precise

21 digging, and that is supposed to work, and

22 that is not going to involve staging areas

23 and access roads. It's very

24 disappointing.





32

1 I think we're doing this

2 sideways and it's more of a political than

3 a community process. And we really just

4 don't see how, in terms of the things that

5 we feel we should be able to know about

6 and comment about, you issue a permit, and

7 the impact hasn't even been talked about

8 as far as we're concerned. So we're very

9 discouraged.


11 MR. FEDERER: My name is Eric

12 Federer, F-E-D-E-R-E-R. Eric with a C. I

13 have a question, if I may ask it? Does

14 anybody know what the chemical half-life

15 is of PCBs and the most heavily

16 chlorinated; does anybody know that?

17 Okay, thank you.

18 MS. CIANFARINI: My name is

19 Barbara Cianfarini, C-I-A-N-F-A-R-I-N I.

20 I live in Pittsfield and I'm the acting

21 executive director for Citizens for PCB

22 Removal. And I also would like to thank

23 the EPA for the many, many years of very

24 difficult, complex, and sensitive work





33

1 that they have done addressing this mega

2 problem. And thank you for sticking to

3 it, not abandoning us, and thank you for

4 listening to us. And by us, I am

5 including the organizations of HRI; BEAT,

6 Berkshire Environmental Action Team; HEAL,

7 Housatonic Environmental Action League;

8 HVA, Dennis already spoke; and BCRPC,

9 Berkshire County Regional Planning

10 Commission, Nate Karns; and others who

11 have had advocated so hard for this river

12 over at least two decades of work, and in

13 some cases more than three decades. And

14 thank you for incorporating in this plan

15 some of the things we have advocated so

16 hard for, including the fact that you're

17 not proposing any onsite toxic waste

18 dumps, as unfortunately the previous part

19 of the cleanup had, Hill 78 and Hill 71.

20 Thank you for advocating for the use of

21 rail. We do believe it's a lower impact

22 to the community and, in fact, will be an

23 asset to the community when everything is

24 done, because we believe the rail system





34

1 will have to be improved and brought up to

2 standards. So then Berkshire County will

3 have that to use afterwards. And we are

4 happy that you are looking to remove it

5 and transport it out. Again, no dumps.

6 Although we would like to see more use of

7 the adaptive management which you also

8 included to hopefully treat it in situ and

9 not have to have the rail transport or any

10 other kind of transport, which addresses

11 many of the concerns of the abutters to

12 this next process.

13 However, and there is always a

14 however, we echo the concerns of our

15 colleagues who have spoken before us, that

16 the 25 percent proposed removal is nowhere

17 near enough. That 75 percent left behind

18 is frankly outrageous. If you had any

19 other situation, if you had a cancer to

20 remove, you would not remove 25 percent of

21 a cancer and leave 75 percent behind. If

22 you were treating another disease, you

23 would not aim for 25 percent abatement of

24 that disease; you would be looking for as





35

1 close to 100 percent as you could.

2 We -- it's obvious to us that

3 most of the contamination, based on the

4 PPMs of 49 PPMs are obviously in the core

5 areas and below the caps. And while no

6 one is advocating for the destruction of

7 the river, we -- it's not a goal, it's not

8 something we want to see; it just has to

9 be done in a way that gets rid of the

10 poison. This is a poison. And we cannot

11 leave it here in any form, in any area

12 where it can expose wildlife and human

13 beings in the future. It just doesn't

14 make sense as many other people have said.

15 And if it's left in the core areas, it

16 will impact the core areas. It's great

17 that there's rare and endangered species,

18 but why are they endangered. Could it be

19 because they are exposed to PCBs. And

20 there is no doubt in our mind that it will

21 recontaminate the entire system in the

22 future if it's left there in that amount,

23 75 percent of the total known

24 contamination. That's not even accounting





36

1 for what might be found that was not found

2 to date.

3 We believe that more is more,

4 not less is more. And we ask that you go

5 for the full monty, so to speak. And

6 people have not talked about the cost here

7 too much and that is a factor. But

8 frankly, the difference between 613

9 million and 900-and-something million is

10 only a 50 percent difference. And if you

11 get the 75 percent, that is 50 percent or

12 three times the value in that last 50

13 percent cost. So we believe you should be

14 looking more towards the bulk cleanup that

15 was proposed, because it's actually a

16 bigger bang for everybody's buck,

17 including GE's.

18 And we would also like to go

19 on record as Citizens for PCB Removal and

20 as a home owners' group to start with, we

21 have gone through the experience of having

22 remediation done on properties and we know

23 the process and we know how to advocate

24 for a better process and we are offering





37

1 our assistance to any homeowner out there

2 who would like that for themselves. You

3 do have a right to make comments. You do

4 have a right to influence this for the

5 better for yourself.

6 We also appreciate the

7 extended comment, written comment period

8 or comment period in general and we will

9 be submitting further written comments as

10 well.

11 And I would like to say one

12 more thing and that is that the basis of

13 this being capping, we just don't believe

14 in capping. Caps fail. That is the

15 bottom line. Caps fail. And especially

16 when caps are made out of nothing more

17 than the same material that is in the

18 river. That material moves around. There

19 is really nothing to prevent the cap from

20 moving around. And a prime example of

21 that is the fact that just weeks after the

22 Silver Lake project was finished to

23 fanfare and ceremony, we had a relatively

24 minor rain storm for Berkshire County, and





38

1 the cap of part of Silver Lake failed. I

2 can't think of any better example than

3 that.

4 Caps do not work, cleanup

5 works, removing works, treating it works,

6 getting rid of it works. Thank you.


8 MR. GRAY: Tim Gray,

9 Housatonic River Initiative. About

10 probably five, six years ago, EPA had GE

11 do the corrective measure study, and in

12 that corrective measure study was a very

13 complete cleanup plan, very strong cleanup

14 plan. Then State of Massachusetts started

15 meeting with General Electric. And then

16 after that the State of Massachusetts

17 started meeting with the EPA. Before we

18 knew it, we had a weak cleanup plan. And

19 the cleanup plan is so inadequate that I

20 believe it will leave the river

21 contaminated forever. I don't think the

22 river will have any hope to recover. So I

23 think it needs to be a much stronger

24 cleanup plan.





39

1 I also want to remind that we

2 have the highest levels in ducks and fish,

3 definitely in the United States, and

4 possibly in the world, and it begs to

5 clean up the river for all the critters in

6 the river. I posed a question to the

7 state one time that we have those kind of

8 levels in the fish, and they said, Tim,

9 it's okay, because we have stable

10 populations. So I said, so we have stable

11 populations of contaminated fish and

12 ducks. And the first duck that was tested

13 had 3,700 parts per million, an astounding

14 level of PCBs. And, of course, there was

15 an ecological risk assessment that was

16 done by EPA and GE. I think it lasted

17 about five years and cost the taxpayers

18 probably millions and millions of dollars.

19 This was back about 2003. And now it's

20 being ignored. So all of that taxpayer

21 money goes down the tubes. And that

22 report was written to make sure that we

23 take care of the critters in the river.

24 As far as capping goes, I





40

1 would like to go back to Allendale School

2 in Pittsfield. Allendale School was

3 capped back around 1993. And the people

4 who live in the neighborhood asked that it

5 be monitored. And every two years they

6 tested the capping. And this is on land;

7 it's not a water-based cap. And every two

8 years it failed. And they had to go back

9 and fix it, find the spots that were

10 popping up contaminated. Eventually they

11 excavated the school, because the cap did

12 not work. So now we're going to take the

13 cap into the river where there's

14 hurricanes and different things that

15 affect the river, and we expect it to

16 withstand those kind of pressures. So

17 caps, at least at Allendale School, proved

18 that they just don't work.

19 This thing about no landfill

20 in Berkshire County, the EPA allowed GE to

21 landfill next to Allendale School. And I

22 believe that what we know from rumors in

23 the neighborhood that GE is buying land up

24 around the county and getting purchase





41

1 agreements in place. I don't think they

2 would be doing that if they think that

3 they are going to have to, you know, truck

4 it out of the neighborhood. And the other

5 thing is that landfilling next to

6 Allendale School is precedence. So I

7 think they could go before a judge and

8 say, hey, wait a minute, we have done it

9 before; you should allow us to do it

10 again.

11 Adaptive management should be

12 on the table; it should be thorough; it

13 should be slow; it should be incorporated

14 community into that. Not just be

15 something that is decided in Boston. I

16 think that is important.

17 And my last point is that

18 there is a bigger reason than cleaning the

19 PCBs in the Housatonic River, is that

20 everything on the earth is contaminated

21 with PCBs, every animal, every human

22 being. The polar beers are getting sick,

23 orcas are getting sick, beluga whales are

24 getting sick, animals on the Housatonic





42

1 River are getting sick according to the

2 ecological risk assessment. And I think

3 we need to clean up because of that.

4 Thank you.


6 MR. FRIEDMAN: Good evening.

7 My name is Benno Friedman, B-E-N-N-O,

8 F-R-I-E-D-M-A-N. I'm with the Housatonic

9 River Initiative. I'm a current board

10 member.

11 I don't think it makes any

12 sense nor is it going to convince anyone

13 if I cite more numbers and facts. The

14 numbers and facts, in fact, are very well

15 known, if not discovered by EPA in the

16 surveys and studies that they have

17 conducted. And what we have here is a

18 situation where science is being trumped

19 by politics. Science is being trumped by

20 power. Science is being trumped by forces

21 that are outside of the vision of most of

22 the rest of us. And certainly out of

23 sight of the media. And it should not be

24 any surprise that that is the way that





43

1 things work, because we're looking at the

2 issue of global warming, and in this

3 country, we seem to have a very strong

4 precedence right now for ignoring science.

5 If you went to buy a house and

6 the house looked beautiful, and its walls

7 were freshly painted, and the carpets were

8 brand new, and the lawns appeared to be

9 healthy, would you buy the house if you

10 knew that you had to live in a house

11 filled with mold that was behind those

12 walls that was waiting to come out and

13 impact your family at some point?

14 If you went and bought a car

15 and the car was freshly painted and it

16 sounded good, but somehow you found out

17 that it was all a fresh coat of paint over

18 a rusted and imperfect and a motor that

19 was about to fail, would you buy that car?

20 We're fortunate in that we

21 don't have to live in the river or the

22 river environment. We live nearby it, but

23 we don't have to live in it. So who is

24 going to advocate for the living creatures





44

1 that do live in it if not the

2 Environmental Protection Agency. They are

3 living in the rusted car, the broken down

4 car. They are living in the house filled

5 with mold. And you're proposing to put a

6 fresh coat of paint on the house and on

7 the car.

8 I'm glossing over it a little

9 bit. I understand there is work to be

10 done. But to say that you're leaving as

11 much as you have in written form, in

12 detailed written form within the proposed

13 remedy, is a crime against the very

14 environment that you're supposed to

15 protect. You have stated for many years

16 that the EPA has the ultimate

17 responsibility and authority to make the

18 decision unilaterally when it comes to

19 environmental groups and all the others

20 that have spent fifteen-some-odd years

21 sitting around the table listening to

22 information, giving their comments, and

23 what have you. Repeatedly we have been

24 told we have no authority.





45

1 And yet some authority seems

2 to have occurred somewhere that has the

3 power over you. Because you had a very,

4 very strong cleanup a couple of years ago

5 being proposed. And suddenly your

6 authority seems substantially diminished,

7 and the cleanup seems substantially

8 diminished. And we were left wondering,

9 who among the powerful have gotten to you

10 and excised the science and marginalized

11 the decades of work that you, yourselves,

12 have put into those studies that speak

13 louder than any voices tonight, dictating

14 a required cleanup that goes far beyond

15 what you propose.

16 I ask you to, once again,

17 assert your authority and provide us with

18 a beacon of hope in being the

19 environmental protection authority that we

20 hoped you would be. Thank you very much.


22 MR. CIANFARINI: My name is

23 Charlie Cianfarini, you remember how to

24 spell it, same as Barbara. Citizens For





46

1 PCB Removal.

2 This plan was developed with

3 many considerations and compromises.

4 Unfortunately, these compromises leave 75

5 percent of the total contamination of this

6 toxic pollutant. The most intensive plan

7 of those originally considered and

8 proposed was to take longer than thirteen

9 years. The longest and most intensive

10 proposal should be the one included in

11 this permit.

12 At a public meeting in

13 Pittsfield, one city official said that

14 PCBs escaped into the river. For the

15 amount of contamination that is in the

16 river, this escape would be the equivalent

17 of all prisoners in the jails of this

18 country to be let out at once. These PCBs

19 did not escape from the GE plant, but were

20 dumped into the river.

21 We expect that GE will

22 litigate any permit. They might as well

23 fight a full cleanup rather than this

24 limited and inadequate proposal.





47

1 We also need to remember that

2 any PCBs left in the river will eventually

3 become dislodged, recontaminate our

4 communities, and flow down to our friends

5 in Connecticut. It is a gift that I don't

6 want to give them. Thank you.


8 Others wish to go make a

9 statement for the record?

10 MR. KRONBERG: Carl Kronberg,

11 C-A-R-L, K-R-O-N-B-E-R-G. I live in

12 Lanesboro, Massachusetts. As a point of

13 reference, I have been a citizen activist

14 for over forty years, including working

15 for Citizens Action in New York, giving

16 technical support to Love Canal; working

17 on the New Horizons Committee to clean up

18 the Buffalo River after Bethlehem Steel

19 left Lackawanna, New York; on the

20 committee to suggest economic initiatives

21 in response to the closing of Louisiana

22 Pacific in Ketchikan, Alaska; a field

23 supervisor for the Department of

24 Commercial Fisheries of the Alaska





48

1 Department of Fish and Game; on the board

2 of Trout Unlimited in Cody, Wyoming and

3 the State of Wyoming Water Advisory Board;

4 past president of the Taconic chapter of

5 Trout Unlimited; and a member of the

6 committee that initiated the recognition

7 by the State of Massachusetts of the area

8 called the "Rest of the River" designation

9 as an area of critical environmental

10 concern.

11 First, I would like to

12 compliment the EPA staff for the thorough

13 job they did in the scientific studies of

14 the Housatonic River, that include the

15 ecology of the river, its history, and, of

16 course, its contaminants, in reference to

17 the PCBs dumped in the river and its

18 surrounding environment from 1930 to 1977

19 by GE. I went to most of the workshops

20 and the more recent series called a

21 charrettes.

22 Second, even though it was not

23 within the scope of the study, I would

24 like to suggest that further study be





49

1 undertaken to identify other contaminants

2 found in the river and the potential

3 health hazards to humans and the

4 environment.

5 Third, any cleanup should

6 clearly express the restoration that would

7 be part of the process and involve the

8 community.

9 Fourth, recently scientists

10 have come to recognize the positive role

11 rivers have on climate change. While not

12 in the scope of this issue of the

13 importance of the health of the rivers

14 under the Clean Water Act, it should be

15 addressed in plans for river cleanups in

16 any current and future river projects.

17 Fifth, my reaction to the

18 proposal for the Rest of the River is not

19 unexpected disappointment. The science

20 points to a need for a much more thorough

21 cleanup of the Housatonic River and the

22 adjacent environment. The scientific

23 analysis should have led to a more

24 thorough cleanup, but I believe it was





50

1 stymied by the efforts of GE to minimize

2 the cost of the cleanup and by its ability

3 to influence the economic and political

4 culture of Pittsfield and the State of

5 Massachusetts.

6 It may be anecdotal, but

7 individuals have said in public meetings

8 and to me personally that they and their

9 families would not go near the Housatonic

10 River until it was cleaned up.

11 I guess my felling is that all

12 is not lost, because I think eventually

13 future generations will recognize the

14 value a clean river will provide to this

15 community both economically and as

16 recreational tourism. And they will take

17 pride in doing the right thing. Thank

18 you.

19 MR. BERKEL: Hi, good evening.

20 My name is Brian Berkel, B-E-R-K-E L. I

21 live on East New Lenox Road, and I can see

22 the river right from my front yard. I

23 can't see Russia from my back porch, but I

24 can see the river across the way.





51

1 My biggest concern here at

2 this point as a resident in the

3 neighborhood is just to be able to have a

4 better understanding so that I can be a

5 better participant in this conversation as

6 to what the logistics are going to be for

7 these trucks coming and going from the

8 neighborhood. I'm echoing what Mr. Cook

9 had said in that we just need to know.

10 And I would think that we should have that

11 information up front, so we can be a

12 better participant in the conversation.

13 And I think that you guys should owe it to

14 the stakeholders, the property owners, the

15 families who are going to be impacted most

16 over this five years or more. That is

17 all. Thank you.


19 MR. ALSOP: My name is Danny

20 Alsop, A-L-S-O-P. I live in Stockbridge,

21 about 200 yards from the river. And back

22 in 1989 I received an EPA award for

23 canoeing across Massachusetts for rivers,

24 river protection. And I have been





52

1 involved in river protection since then a

2 bit.

3 I just came back from Maine,

4 where I started over a period of time at

5 Bar Harbor and I ascended the Penobscot

6 River to Mt. Katahdin, which I climbed.

7 And I thought about the Housatonic the

8 whole way. And then I went across Maine.

9 I went up the west branch of the Penobscot

10 and down Mooshehead Lake and up Moose

11 River and eventually to Flagstaff Lake and

12 up the Dead River. And everywhere I went,

13 I saw a river. Most of the land that I

14 traveled through has been changed by man.

15 The landscape of Maine is the landscape of

16 old mills, old dams, old industries which

17 have left. Old agricultural and logging

18 practices which have peaked and failed and

19 which have changed the landscape,

20 releasing vast tons of soil from

21 mountainsides down into the river,

22 changing the river, creating wetlands,

23 where there were no wetlands, altering the

24 speed of water. And much of this has





53

1 happened in the last 150 years. I saw

2 change.

3 In my travels on the

4 Housatonic River, I mostly go upstream.

5 When I cross the state I had to go -- I

6 had to learn to go upstream. And this

7 gave me a different perception of the

8 river. When you start at the river, you

9 look down in salt water through the clear

10 water at the ground below you, below the

11 water, and what do you see? You see the

12 same pattern. You see the same pattern

13 that you see at the mouth of the Ipswich

14 River, the Connecticut River, the

15 Housatonic River, the Hudson River. It's

16 the same pattern. It's the pattern of

17 energy and water moving, okay.

18 So I'm hear to say that I

19 don't think, in my opinion, that you can

20 kill a river. You can alter it, and it

21 will self-correct. It will not do what

22 you want to do, but it will do what it

23 wants to do. It's only a matter of time.

24 Three hundred yards from my





54

1 house in Stockbridge there is the outside

2 bend of the river, where the soil gets

3 picked up and carried downstream and

4 redeposited on the inside of the next

5 curve. On the inside of that bend, just

6 specifically at eye level, were a series

7 of holes in the bank, bank swallows, part

8 of our natural balance between the bugs

9 and everything else. Two pulses of water

10 in the last year took the first hatch of

11 these birds and swept them away. The

12 birds came back and drilled the holes

13 again and then they got wiped out again.

14 And now those birds are gone. But they

15 have gone somewhere else. They follow the

16 river. And so do the forms we know as

17 river move, and so do the species of trees

18 and plants and fish and animals move. So

19 I say, let's remember, no matter what we

20 do, we cannot kill the river. The river

21 will keep doing what it's going to do. My

22 advice is work with that. Don't get stuck

23 with a fixed idea of what river is.

24 Recognize that it is alive. That is the





55

1 best thing I can say.


3 Others wishing to make a

4 comment?

5 MR. deFUR: You said we might

6 have. Peter deFur again.

7 Three points that not have

8 been talked about at all. Number 1 is,

9 there is a performance standard for fish

10 tissue concentrations of PCBs. In fifteen

11 years, they need to reach -- be low as 1.5

12 milligrams per kilogram. But 1.5

13 milligrams per kilogram is manyfold in

14 excess of the recommendations that EPA has

15 for PCBs in fish tissue, for human

16 consumption. In fact, states up and down

17 the East Coast have one of two standards.

18 And that is not in parts per million, it's

19 milligrams per kilograms. But it's in the

20 parts per billion. And they tend to be

21 either 5 parts per billion or 50 parts per

22 billion. And 1.5 milligrams per kilogram

23 would be 1,500 parts per billion. That

24 number doesn't protect human health at





56

1 fish consumption rate, which is considered

2 to be anything more than just minimum. It

3 also won't protect for anybody who already

4 has PCBs in their body.

5 The other point I want to

6 raise that has not been mentioned except

7 in the very vaguest of terms is

8 Connecticut. Nothing is being done in

9 Connecticut. I have raised this point for

10 over ten years here, that EPA does not

11 have enough data to write off the State of

12 Connecticut. They need to have insisted

13 on further sampling and at a minimum, they

14 need to have sediment removed from behind

15 the dams in Connecticut. I hate to see my

16 home state, the waters I grew up swimming

17 in, remain polluted in such a way.

18 And the third point that has

19 not been made at all is that this plan

20 would offer probably the most modest PCB

21 remediation of any major contaminated site

22 in the nation. I have been doing this for

23 over twenty years and I have not

24 encountered a PCB-contaminated site of





57

1 this magnitude that has received a

2 proposed cleanup this minimal. It really

3 does stand out. In twenty years of

4 experience across the nation from Seattle

5 to Massachusetts to the Gulf Coast, it's

6 the least. And I don't think it meets EPA

7 standards and I don't think it's up to the

8 quality of what the National Remedy Review

9 Board would have expected out of this

10 region. Thank you.


12 MS. BARZOTTINI: I don't know

13 how to follow all these eloquent speakers.

14 My name is Thelma Barzottini, that's

15 B-A-R-Z-O-T-T-I-N-I. I live in

16 Pittsfield, Massachusetts.

17 I have just said it all

18 before. I just want to thank all the

19 eloquent speakers and the EPA for coming.

20 I just go on record, I don't believe in

21 capping. You can't leave it there. You

22 have got to think about the health to the

23 people and the habitats of the river. And

24 I always say, I know Pittsfield had a





58

1 Consent Decree, but I'm quite happy with

2 what happened there. I hope that the Rest

3 of the River, they could set up some pilot

4 programs, it would go for the new

5 technology that is out there.

6 I really don't know what else

7 to say. I guess I have said it over and

8 over. I just -- the Rest of the River, I

9 don't approve of, I never approved of

10 capping at all. I don't think it survives

11 properly, and if you do it in the river

12 with the weather conditions and so forth.

13 And as I say, everybody before me more or

14 less said what I would have said. And I

15 thank you.


17 MS. MILLER: My name is Claire

18 Miller. I'm the Massachusetts State

19 Director of Toxics Action Center. We have

20 offices in Boston and Amherst. We are a

21 public health and environmental nonprofit

22 and we were founded in the '80s after the

23 Woburn cancer cluster.

24 I want to echo by also saying





59

1 that it's hard to follow all of these

2 really eloquent speeches. And I have not

3 had a full chance to dig my way through

4 the permit, so I'll be sending more

5 thorough comments before the end of the

6 comment period.

7 Sitting here tonight though,

8 listening to other folks speak from the

9 heart about how they feel about this, I

10 can't help but remember how I came to be a

11 toxics community organizer, which is not

12 the most straightforward life path. But

13 when I look back on my life, I can't help

14 but notice that I grew up ten miles from

15 Pilgrim Nuclear Power Plant, and it's very

16 clear to me that even at a very young age

17 I knew it was there and had some kind of

18 understanding that it could completely

19 destroy my community and my neighborhood

20 and my family. And I don't think there is

21 any better memory that crystallizes what I

22 mean then to share with you when I was

23 about nine-years old. I heard the

24 lighthouse fog horn, but I thought it was





60

1 the siren for nuclear meltdown and woke my

2 parents up, convinced that we had to

3 evacuate. And that's a really strange

4 memory, it's a really strange knowledge

5 for a child to have.

6 And I'm not from the

7 Berkshires, I don't have that kind of

8 connection to the Housatonic River, but I

9 can imagine that families and children

10 have that same kind of knowledge and fear

11 about being contaminated.

12 And so I would urge you all,

13 as you listen to all of these stories and

14 hear the comments, to be as aggressive as

15 possible, remove as many PCBs as possible,

16 because all, you know, all types of

17 containments, you know, eventually fail.

18 And so we need to be as aggressive as we

19 can the first time around, while we still

20 have as many people as possible involved

21 in the process.

22 And you know at the end of the

23 day, Toxics Actions and I believe that we

24 all have the right to breathe clean air,





61

1 drink clean water, and live in healthy

2 communities. And so doing the best

3 possible, removing more than just 25

4 percent, I think, is a major piece of

5 that. Thank you.


7 Any others wishing to make a

8 statement before I close the hearing?

9 Hearing none.

10 Thank you all for coming this

11 evening and for your interest in this

12 Draft Permit. We do have extra copies of

13 the Draft Permit and the Basis available

14 outside the door. In particular, Pages 42

15 and 43 provide locations where you can

16 review development documents and how to

17 provide EPA with written comment.

18 And as we mentioned earlier

19 the public comment period closes on

20 October 27, 2014.

21 This closes our public

22 hearing. Thank you.

23 (Hearing adjourned)

24



------------------------


62

COMMONWEALTH OF MASSACHUSETTS

I, RAYMOND F. CATUOGNO, JR., Notary Public

Court Reporter do hereby certify that the

foregoing testimony is true and accurate, to the

best of my knowledge and belief.

WITNESS MY HAND September 29, 2014.

C?~~ ------------------------

Raymond F. Catuogno, Jr.

Notary Public

My Commission expires:

February 10, 2021

Springfield 413.732.1157

REAL TIME COURT REPORTING [email protected]

Worcester 508.767.1157





63

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29:7 30:20 31:23accounting 35:24accumulate 8:16,16accurate 62:13accurately 25:11acquired 12:18act 3:12 14:5 49:14acting 32:20action 3:15,18 4:16

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18:16 20:3 34:741:11

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15:13 16:7,20addressed 13:10

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33:1adjacent 49:22adjourned 61:23administrative 4:13advanced 10:21advantage 25:21adverse 9:22advice 54:22advisory 48:3advocate 36:23

43:24advocated 33:11,15advocating 33:20

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54:18

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ascended 52:5asked 6:22 40:4assert 45:17assessment 39:15

42:2asset 33:23assistance 13:11

37:1assistant 7:21associated 8:8association 22:5associations 27:13astounding 39:13attention 12:5attractions 21:17attracts 13:5

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15:16 19:3audubons 14:10authorities 13:1authority 44:17,24

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64

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car 43:14,15,1944:3,4,7

carcinogen 8:24care 12:18 15:6

39:23

carl 47:10,11carpets 43:7carried 54:3case 7:10cases 11:7 33:13catastrophic 17:12

18:2catuogno 1:24

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49:11 53:2changed 52:14,19changes 10:9changing 52:22channel 10:6,7chapter 48:4charlie 45:23charrettes 48:21chemical 32:14chemicals 17:19child 60:5children 9:10 60:9chlorinated 32:16cianciarulo 2:2 3:1

3:2 12:6 14:7 22:226:18 32:10 38:742:5 45:21 47:751:18 55:2 57:1158:16 61:6

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42:3 47:17 49:1450:14 60:24 61:1

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cleanups 49:15clear 16:19 53:9

59:16clearly 49:6climate 17:9 49:11climbed 52:6close 7:12,12 35:1

61:8closely 14:12closes 61:19,21closing 11:11 47:21closure 5:2cluster 58:23coast 55:17 57:5coat 43:17 44:6cody 48:2colleagues 34:15combine 9:23come 3:10 6:12

9:12 21:15,2027:14 30:15 43:1249:10

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comment 4:23 5:3,56:9 7:2,13,1414:19,21 19:122:20 28:13 32:637:7,7,8 55:4 59:661:17,19

comments 5:4 6:3,56:7,8,21,23 7:1,57:8,9,24 12:314:15,19 16:819:11 22:8 37:3,944:22 59:5 60:14

commercial 47:24commission 33:10

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8:11 13:16,2020:6 23:1,6,7,8,1524:6 25:3,1838:21 39:11 40:1041:20 56:21 60:11

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context 17:18continue 8:13,14,15

11:19,20continued 9:1





65

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14:9

cynical 28:12

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66

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67

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68

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