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EPA won’t make GE clean up Newell St. parking lot (3/15/06)The US Environmental Protection Agency (EPA) said at a March 15th Citizens Coordinating Council meeting, that it will not ask General Electric Co. (GE) to investigate what is under the Newell Street parking lot.There is continuing remediation at the Western Mass. Electric Company property abutting the parking lot, with 583 crushed or partial barrels, 371 drums worth of capacitors, and 34 barrels containing some liquid or solids having been removed so far. EPA estimates the removal is 70% complete. GE will follow any “vein” of capacitors or barrels they find into the parking lot, but they will not go looking for what else might be under there. The EPA feels that the percentage of PCB oil that would be found, compared with the amount they know is 40 or so feet below this site is so small that it is not worth the work.BEAT thinks that is depressing! Why not clean up what you can relatively easily reach. If it were in a “clean” area all those contaminated barrel remnants and capacitors would be considered a major problem. It is just in comparison with the bigger mess that this seems small.EPA estimates that there is probably 100,000 gallons of dense PCB oil below the site. So far, GE has pumped out over 36,000 gallons of this oil. The pumping stopped in June of 2005 while the WMECo property is being worked on, but the pumping will resume when the remediation work permits.There are monitoring wells that extend down about 15 feet below ground level into the water table. Ground water flows toward the river and these wells allow EPA to see what concentration of PCBs are being detected flowing toward the river in the location of the wells – between the Newell Street dumping areas and the river. On several separate occasions  levels of PCBs above the GW3 standard have been detected. GW3 is the ground water standard that sets what is an “acceptable” level of contamination for water in the river.The EPA website has more information under “Newell St. Area II” including maps of this area.
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Activities to resume 2/13/2006:  In a letter to the EPA pdf icon, GE is proposing additional excavation activities at the Newell Street Area II barrel field site, based on the investigations conducted over the fall and early winter. In a letter to GE pdf icon, the EPA approved  the proposed activities. BEAT sent comments (addressed to the EPA) to all involved requesting that if contamination (such as barrel remnants or capacitors) continues below the water table, GE be required to remove the contamination or at the very least discuss the issue with the EPA. BEAT also urged the EPA to require GE to take similar action to investigate under the adjoining parking lot and remove any barrels, barrel remnants, and capacitors found there.EPA replied  that based on the test trench results and pre-fill surface elevation of the former oxbow, it is unlikely that there will be a need to continue the excavation below the water table.  However, EPA will be monitoring the excavation activities daily and should something unexpected be encountered during the construction activities, EPA will discuss with GE the need for additional actions, as appropriate.Beginning February 13, GE, under EPA and Mass DEP oversight, will resume excavation activities at the Newell Street Area II site, at the intersection of Newell and Sackett Streets.  Contaminated soil, drum remnants and capacitors encountered during the excavation will be transported off-site for disposal.  Soil will be temporarily stock-piled at Building 68 on the GE facility before being shipped off-site for disposal at a permitted facility.  Any drums that are found intact will be overpacked, sampled and shipped off-site for disposal.  Once the excavation is complete, the area will be restored.For additional information on the upcoming work, please see the press release that follows._________________News Release
U.S. Environmental Protection Agency
New England Regional Office
February 8, 2006Contact: David Deegan, 617-918-1017Excavation Work to Resume in Pittsfield at Newell Street Area II(Boston)  – Beginning next week, work will resume excavating PCB-contaminated soil, drum remnants and debris from the Western Mass.Electric Co. portion of the Newell Street Area II site, at the intersection of Newell and Sackett Streets.  The work will be performed by GE, under the direct oversight of both EPA and the Mass. Dept. of Environmental Protection (Mass DEP).Contaminated soil, drum remnants and capacitors encountered during the excavation will be transported off-site for disposal at a licensed facility.  Soil will be temporarily stockpiled at Building 68 on the GE facility before being shipped off-site for disposal at a permitted facility.  Any drums that are found intact will be overpacked, sampled and shipped off-site for disposal.  Once the excavation is complete, the area will be restored and re-vegetated.An estimated three- to four- thousand cubic yards of additional material will be removed over the next two months, bringing the total volume of material removed from the parcel to approximately 16,000 – 17,000 cubic yards.  The additional excavation work is based on investigations conducted over the fall and early winter after which it was determined that additional excavation to approximately twice the depth than in the original plan.Throughout the cleanup, measures will be taken to suppress any dust and minimize odors at the site to ensure that the cleanup activity does not impact the air quality of nearby residents or pedestrians in the vicinity of the work area.  As an added precaution, both EPA and GE will perform air monitoring during the clean up.Initial excavation at Newell Street began late last summer.  During the excavations, a large number of drums and capacitors were encountered on  the property.  These discoveries resulted in EPA, Mass DEP and GE conducting a series of non-invasive, subsurface investigations (called geophysical investigations) to further define the presence and extent of drum debris and capacitors.Following the geophysical surveys, 18 trenches totaling approximately one thousand linear feet were dug in areas of the site to confirm the accuracy of the geophysical survey.  Drum remnants and capacitors were encountered in 16 of the 18 trenches at depths ranging from four to six feet.To date, 583 empty drum remnants and 34 drums containing liquid have been removed and sent off site for disposal.  In addition numerous small capacitors have been discovered and disposed of through appropriate, protective mechanisms.The EPA website has more information under “Newell St. Area II.”return to top
BEAT’s letter to the EPA 2/10/06William Lovely
US EPA
One Congress St., Ste 1100
Boston, MA 02114-2023Re:     GE’s letter of January 18, 2006
GE-Pittsfield/Housatonic River Site
Newell St. Area II (GECD450)
Proposal for Additional Removal ActivitiesDear Mr. Lovely,Thank you for getting GE to agree to more remediation at this site than they believe is required under the Consent Decree.I applaud your decision to have GE reuse the stockpiled material previously used as backfill only below the three foot level.In GE’s letter of January 18, 2006, Proposal for Additional Removal Activities, GE states on page 3 of 4, “However, in the event that excavation activities extend… vertically to locations below the water table, GE will discontinue the removal operations.” GE also states that this is not expected to happen. First, I believe that if the excavation activities extend below the water table it is very important to remove any barrels, barrel remnants, capacitors or other source of contamination. To that end, I would ask GE to de-water the area and continue excavation to the extent that the contamination exists. At the very least, I would want to be sure that GE notifies the EPA if this situation arises and discusses how to proceed. Perhaps it would be just a matter of timing, so that waiting a period of time the water table might drop to a point where excavation could continue. I think it is unacceptable to leave contamination in the water table. That contaminates the ground water and the ground water will move over time.Thank you also for specifying that your conditional approval does not imply anything about the rest of the property. BEAT again urges the EPA to require GE to take similar action to investigate under the parking lot and remove any barrels, barrel remnants, and capacitors found there.Sincerely,Jane Winn
–Jane Winn
413-442-6815
jane@thebeatnews.org
BERKSHIRE ENVIRONMENTAL ACTION TEAM (BEAT)
Working to protect the Environment of Berkshire County, MA
Send your tax deductible contribution to:
BEAT, 27 Highland Ave., Pittsfield, MA 01201-2413
or on line at: www.thebeatnews.org
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December 14 Report           The good news -EPA heard your calls to get rid of all the barrels and capacitors. The 3 different types of geophysical monitoring appear to have been accurate in detecting where the barrels were – not so good at detecting capacitors. GE dug trenches in suspect locations and developed a plan for removal that EPA agreed to. in all the locations where more barrels and capacitors have been identified GE will remove down to at least 6 feet, more if there are still barrels or capacitors there.So far they have removed 13,000 cubic yards of material, 583 drum remnants, 34 drums with some amount of liquid, and 371 drums-worth of capacitors. (Capacitors are about the size of a soda can. These get put into 55 gallon drums… 371 55 gallon drums worth of them.)The bad news -GE will not have to retest the remaining soil to see what the remaining contamination levels are. Instead, they will still put a cap where ever the original testing showed that the contamination levels were going to be above an average of 100 parts per million – regardless of what the levels really are.While BEAT is glad there will be a lot less contamination, we are sorry not to know how much is being left in place. We are also sorry to have more capping in the floodplain.

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October 31, 2005 Report The barrel field:It sounds like the EPA really will have GE remove all barrels, capacitors, and other metal at the Newell Street Area II barrel field. Previously, EPA had been saying they would not make GE remove any contaminated soil beyond what was planned before the barrel “discovery”.This must change! At the October 19 presentation to the Citizens Coordinating Council, EPA had a diagram of how much contamination could be left in the soil. As drawn, it was comforting. Less than 10 parts per million (ppm) in the first one foot layer of soil. Depending on use and the owner, 10 to 15 ppm in the one foot to three foot level. And in the three foot to fifteen foot level, 100 ppm. HOWEVER, that is not what EPA says is going to happen as currently planned. Anywhere they can not easily achieve the 100 ppm in the lowest level, they will install a barrier at the three foot level, and leave the contamination in the ground.BEAT called upon the public to  tell EPA: we want the barrel field cleaned to less than 100 ppm at the 3 to 15 foot level, thus eliminating the need for a barrier at the three foot level.The reason to remove the contamination rather than use a barrier is simple. Under the current plan, GE will put a barrier at the three foot level to “prevent” contamination from coming back to the surface where it could be an exposure path to people. BEAT believes, the warranty on the barrier (geotextile liner) is void if it comes in contact with hazardous waste, which the high levels of PCBs are. For Hill 78 low level toxic waste dump next to Allendale School, EPA has made the point that the liner covering the Hill will not be exposed to hazardous substances, in part because the ground water will not rise to the level of the liner. That is not the case at the barrel field site. There is nothing to stop the PCBs from migrating to the river.There are some wells to monitor ground water that collects in them so they might know if some PCBs are migrating, if the wells are in the right place to capture the migrating plume. At what level of contamination will they do something about that? How will the public know without reading all through the monthly reports? And why not just remove the contamination             now while the site is already dug up?The parking lot:GE is pumping thousands of gallons of contaminated ground water from under the parking lot right next to the Newell St barrel field. Ex-GE workers are saying the land under the parking lot was also used to dump barrels. Probably there are just as many barrels and capacitors under the parking lot as there were in the barrel field next to it. Some of the contamination will get into the river if it is not removed. Pumping will never fully protect the river.BEAT called upon the public to  tell EPA: we want the parking lot remediated the same way we want the barrel field remediated: Remove all the barrels, transformers, and capacitors and remove the contaminated soil to a level of  100 ppm from 3 to 15 feet. GE owes the citizens a clean river. GE must clean this site as a step in toward that goal.return to top
October 21, 2005 Report: Jane Winn of BEAT, attended the Citizen Coordinating Council meeting on October 19th about the current state of investigation and removal at the Newell Street Area II barrel field. After that, she went back and reviewed some of the studies on this site at: http://www.epa.gov/region01/ge/thesite/ffoxbows-reports.html (scroll down to Newell Street Area II) Here is what she has to say.
October 21, 2005
Re: Newell Street Area II barrel field I object to the plan to leave highly contaminated soil in place and                 just cover it up with a barrier on this site right next to the Housatonic River.
Here are a few highlights from the meeting on the 19th:

The geophysical surveys have been completed and they are just beginning to look at the data.
The originally planned excavation resumed on October 11 and will continue as planned.
The excavation has now unearthed, as of the 19th, 310 drums or drum remnants with no liquid, 31 drums with liquid, and 217 drums-worth of capacitors. These capacitors were in a site much closer to the river.
They will remove all the drums and capacitors that they find.
They will not do any further soil tests – they tested every 50 feet at the one foot depth and every 100 feet deeper than that down to fifteen feet.
The deep tests already showed high levels of contamination.
There are monitoring wells around the property.
More than 36,000 gallons of contaminated liquid have been pumped from under the adjacent parking lot.

At the meeting on the 19th, the US Environmental Protection Agency (EPA) made clear that they still have no intention of doing any more testing of the soil – even beneath the barrel fields. It appeared they will not require GE to remove any more of the highly contaminated soil than was already planned. They will however remove any barrels or capacitors that the might find with the scan.[I have used the pronoun “they” because it is very confusing as to when the responsible party is GE, EPA, Mass. DEP, or a contractor for one of these three.] They did the scan, and then resumed digging. In the new digging they discovered more barrels and the capacitors.

I have asked that, after they examine the scans and determine where they believe more barrels or capacitors might be found, they see if the areas where they already did find more barrels and capacitors are among the areas they would have looked at based on their scans. In other words, if they had not done more digging, would the scans have correctly identified the areas that did in fact have barrels and capacitors. When I looked at one of the three types of scan, and compared that to where it appeared the capacitors were found, I didn’t see evidence of the capacitors in that scan. This doesn’t mean anything, but it raises the question of can you find barrels and capacitors by these scans. If you can, the ones already found should show on the scans.

EPA had a diagram of how much contamination could be left in the soil.  As drawn, it was comforting. Less than 10 parts per million (ppm) in the first one foot layer of soil. Depending on use and the owner, 10 to 15 ppm in the one foot to three foot level. And in the three foot to fifteen foot level, 100 ppm. HOWEVER, that is not what is actually going to happen as currently planned. Anywhere they can not easily achieve the 100 ppm in the lowest level, they will install a barrier at the three foot level, and leave the contamination in the ground.

Exposure of people on the ground:

They will put a barrier at the three foot level to “prevent” contamination from coming back to the surface where it could be an exposure path to people. I believe, the warranty on the barrier (geotextile liner) is void if it comes in contact with hazardous waste, which the high levels of PCBs are. For Hill 78 low level toxic waste dump next to Allendale School, EPA has made the point that the liner covering the Hill will not be exposed to hazardous substances, in part because the ground water will not rise to the level of the liner. That is not the case at the barrel field site.

Run off to the river:

There is nothing to stop the PCBs from migrating to the river. There are some wells to monitor ground water that collects in them so they might know if some PCBs are migrating, if the wells are in the right place to capture the migrating plume. At what level of contamination will they do something about that? How will the public know without reading all through the monthly reports? And why not just remove the contamination now while the site is already dug up? They are pumping thousands of gallons of contaminated ground water from under the parking lot.

I am not quite clear on why this means the contamination not under the parking lot would go to this pump instead of to the river? And why do we want it to go to the pump, not just be removed right now? Even if much of it goes to the pump, won’t some of it remain in the soil? PCBs adhere pretty well to soil particles. And again – why not just remove the contamination now while the site is already dug up? I just do not understand. Why not just dig up the highly contaminated soil? I would also ask that the highly contaminated soil from under the adjacent parking lot be removed as well.

Jane Winn

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Barrel Field Uncovered GE agreed to remove about 12,000 cubic yards of soil at Newell Street Area II, but when they started to do this, in August 2005, they uncovered barrels. Although most of the barrels were badly deteriorated, some of the barrels still had liquid “product” in them. They stopped excavating to study the problem.A geophysical survey was done including two different kinds of scan for metals and a sonar scan as well to determine where more barrels might be located. A flood delayed some of the work, but on October 11, they resumed the original excavation, while beginning to analyze the scan data.On October 19, EPA and DEP met with the Citizens Coordinating Council to explain what was happening at the site. Since resuming excavation, they discovered an area near the river filled with capacitors. They filled 217 fifty-five gallon drums with these capacitors. They also               found more old barrels – for a total of 310 empty, crushed, or partial barrels and 31 still containing liquid. The ones containing liquid are put into bigger barrels and shipped to Texas – and the liquid is tested for PCBs and other contaminants. Any solids including the capacitors, solid contaminants, and soil with more than 50 parts per million (ppm) of PCBs go to a waste area called Building 71 (not really a building, but a lined landfill next to Allendale Elementary School). Soil with PCBs less than 50 ppm go to Hill 78 – an UNlined landfill right next to the playing fields at Allendale Elementary School.EPA explained that the current idea is to look for more drums and capacitors based on the geophysical surveys and remove any they find. They do NOT plan to test the soil beneath the drums. In fact, they know the soil deeper than 3 feet is highly contaminated in many places – so they will put a barrier down at 3 feet to keep that contamination from coming to the surface, and put soil on top that averages less than 10 ppm (or in some places at 2-3 feet deep averages less than 15 ppm).BEAT has several problems with this scenario. First, it does not adequately protect the river. There are some monitoring wells between this site and the river. GE is pumping “product” from underground near by. So the theory is that “product” will not end up in the river.Second, the area just flooded, which goes to show the river does get up above the level of this land… not to mention within 3 feet of the surface. We believe the liner’s warranty is void if it contacts hazardous waste.We do not understand why they don’t just remove all the highly contaminated soil. That would be the end of it.
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