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% REPORT BLASLAND & BOUCK ENGINEERS, P.C. HOUSATONIC RIVER STUDY 90 - Day Interim Report i I .REMEDIAL ALTERNATIVES EV ALUA TION - River Channelization - In - situ Impoundment - Flow and Sedimentation Control General Electric Company Pittsfield, Massachusetts I February 1985 l l

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Page 1: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

REPORT BLASLAND amp BOUCK ENGINEERS PC

HOUSATONIC RIVER STUDY 90- Day Interim Report

i I REMEDIAL ALTERNATIVES EV ALUA TION

- River Channelization - In- situ Impoundment - Flow and Sedimentation Control

General Electric Company Pittsfield Massachusetts

I February 1985l

l

HOUSATONIC RIVER STUDY

90-DAY INTERIM REPORT

REMEDIAL ALTERNAT IVES EVALUAT ION

- RIVER CHANNELIZATION

- IN-SITU IMPOUNDMENT

- FLOW AND SEDIMEtHATION CONTROL

GENERAL ELECTRIC COMPANY

PITTSFIELD MASSACHUSETTS

February 5 1985

This Report was prepared for the General Electric Company by

Blasland amp Bouck Engineers PC 244 Westchester Avenue Suite 405 White Plains New York 10604

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

ACKNOWLEDGEMENT

Portions of this report were prepared by other consultants

Specifically Erseco Inc prepared Sections 3 and 7 Dravo Van Houten

Consulting Engineers assisted in preparation of Section 4 and OBrien amp Gere

Engineers Inc assisted in preparation of Sections 5 and 6 In addition

Erseco Inc assisted Blasland amp Bouck Engineers PC by providing general

consultation and review

TABLE OF CONTENTS

Acknowledgement Page No

Section Executive Summary

Section 2 Introduction 7

21 General 7

22 Purpose and Scope of This Work Effort 8

23 PCB-laden Sediments - Location and Description 8

Section 3 Overview of Applicable Regulations 10

31 Introduction 10

32 Regulatory Interests 10

33 Application of the National Contingency Plan 11

34 Previous Studies 12

Section 4 River Channelization Alternative 14

41 General 14

42 Description of Alternative 14

43 Pre-Construction and Construction Activities 16

44 Scheduling 16

45 Major Engineering Design Considerations 17

46 Major Potential Environmental Impacts 18

Section 5 In-situ Impoundment Alternative 21

51 General 21

52 Description of Alternative 21

53 Pre-Construction and Construction Activities 23

54 Scheduling 24

55 Major Engineering Design Considerations 24

56 Major Potential Environmental Impacts 25

Page No

Section 6 Flow and Sedimentation Control Alternative 28

61 General 28

62 Description of Alternative 28

63 Pre-Construction and Construction Activities 30

64 Scheduling 31

65 Major Engineering Design Considerations 32

66 Potential Environmental Impacts 33

Section 7 Application of Regulations 34

71 Introduction 34

72 Federal Regulations 35

73 State Regulations 37

74 Local Regulations Requirements 41

75 Summary 42

Section 8 Summary and Recommendations 44

81 Summary and Recommendations 44

References

Figures (Located Throughout Report)

General Study Area and Location of PCB-Laden

Sediments

2 Location of PCB Concentration

3 Plan of Channel - Ten Year Storm

4 Conceptual View of River 8efore Channelization

5 Conceptual View of River After Channelization

6 Woods Pond - Present Conditions

7 Woods Pond With Channel

8 Typical Cross Section

Figure 9 In-situ Impoundment - Armoring Typical Cross

Section

lOin-situ Impoundment - Chemical Stabilization

Typical Cross Section

11 Woods Pond and Schweitzer Dam - Existing

Conditions

12 Woods Pond and Schweitzer Dam - Lengthen and

Create a Multiple Stage Spillway

13 Woods Pond and Schweitzer Dam - Approach

Channel Modified

__________um_ -poundyExecutive s __mar ___ BLASLAND amp BOUCK ENGINEERS PC

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 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

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

faci lity 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 major potential environmental impacts and

estimated schedules for project completion A summary of the findings of this

report follows

RIVER CHANNELIZATION

The River Channelization Alternative consists of re-routing portions of

the Housaton ic River by means of a new channel such that the river flow

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does not contact PCB-laden sediments (greater than 50 ppm) This new river

channel is intended to connect river segments with known non-PCB-Iaden

sediments while bypassing those segments with known PCB-laden sediments

The major engineering design and environmental considerations associated

with this alternative are summarized below

1 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a 4-6 week

period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove the Schweitzer Dam and to

drain Woods Pond the backwater areas and the overall river basin

Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

3 Determination of the acceptability of excavated soi Is as emban kment

materials

4 Determination of location of spoil or disposal areas for excess

excavated materials

5 Evaluation of environmental impacts upon the wetland areas

associated with Woods Pond and the backwater areas

6 Evaluation of construction activities upon local transportation

routes

7 Evaluation of impact upon recreational activities within the

Housatonic River Wildlife Management Area

8 Evaluation of the impacts of construction activities upon the local

public

- 2 shy

9 Evaluation of the reduction of groundwater and surface water

avai labi lity and

10 Evaluation of the increase of flood storage volume in the river basin

north of Woods Pond and the effects upon the downstream flood

storage volumes

It is estimated that the overall implementation schedule for the river

channelization alternative would be four to five 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 shy

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 a maintenance and 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 9f potential reduction in flood storage volume 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 six years

FLOW AND SEDIMENTATION CONTROL

The Flow and Sedimentation Control Alternative consists of modifying the

existing Schweitzer Dam below Woods Pond to further increase the ability of

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Woods Pond to act as a reliable and efficient sediment trap for PCB-laden

sediments 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 reservoi r drawdown system to

replace existing raceway

4 There would be no negative impacts on the Wildlife Management Area

or surrounding wetlands and

5 There would be positive impacts 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

- 5 shy

It is estimated that the overall implementation schedule for any of the

flow and sedimentation control options would be two-three 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 gO-Day Interim Reports and will include recommendations for those

alternatives to be evaluated in greater detail within the final 210-Day Report

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BLASLAND amp BOUCK ENGINEERS PC

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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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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

- 7 shy

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

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SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

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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 wi Idlife observation wi II be

significantly hindered

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In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

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SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 2: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

HOUSATONIC RIVER STUDY

90-DAY INTERIM REPORT

REMEDIAL ALTERNAT IVES EVALUAT ION

- RIVER CHANNELIZATION

- IN-SITU IMPOUNDMENT

- FLOW AND SEDIMEtHATION CONTROL

GENERAL ELECTRIC COMPANY

PITTSFIELD MASSACHUSETTS

February 5 1985

This Report was prepared for the General Electric Company by

Blasland amp Bouck Engineers PC 244 Westchester Avenue Suite 405 White Plains New York 10604

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

ACKNOWLEDGEMENT

Portions of this report were prepared by other consultants

Specifically Erseco Inc prepared Sections 3 and 7 Dravo Van Houten

Consulting Engineers assisted in preparation of Section 4 and OBrien amp Gere

Engineers Inc assisted in preparation of Sections 5 and 6 In addition

Erseco Inc assisted Blasland amp Bouck Engineers PC by providing general

consultation and review

TABLE OF CONTENTS

Acknowledgement Page No

Section Executive Summary

Section 2 Introduction 7

21 General 7

22 Purpose and Scope of This Work Effort 8

23 PCB-laden Sediments - Location and Description 8

Section 3 Overview of Applicable Regulations 10

31 Introduction 10

32 Regulatory Interests 10

33 Application of the National Contingency Plan 11

34 Previous Studies 12

Section 4 River Channelization Alternative 14

41 General 14

42 Description of Alternative 14

43 Pre-Construction and Construction Activities 16

44 Scheduling 16

45 Major Engineering Design Considerations 17

46 Major Potential Environmental Impacts 18

Section 5 In-situ Impoundment Alternative 21

51 General 21

52 Description of Alternative 21

53 Pre-Construction and Construction Activities 23

54 Scheduling 24

55 Major Engineering Design Considerations 24

56 Major Potential Environmental Impacts 25

Page No

Section 6 Flow and Sedimentation Control Alternative 28

61 General 28

62 Description of Alternative 28

63 Pre-Construction and Construction Activities 30

64 Scheduling 31

65 Major Engineering Design Considerations 32

66 Potential Environmental Impacts 33

Section 7 Application of Regulations 34

71 Introduction 34

72 Federal Regulations 35

73 State Regulations 37

74 Local Regulations Requirements 41

75 Summary 42

Section 8 Summary and Recommendations 44

81 Summary and Recommendations 44

References

Figures (Located Throughout Report)

General Study Area and Location of PCB-Laden

Sediments

2 Location of PCB Concentration

3 Plan of Channel - Ten Year Storm

4 Conceptual View of River 8efore Channelization

5 Conceptual View of River After Channelization

6 Woods Pond - Present Conditions

7 Woods Pond With Channel

8 Typical Cross Section

Figure 9 In-situ Impoundment - Armoring Typical Cross

Section

lOin-situ Impoundment - Chemical Stabilization

Typical Cross Section

11 Woods Pond and Schweitzer Dam - Existing

Conditions

12 Woods Pond and Schweitzer Dam - Lengthen and

Create a Multiple Stage Spillway

13 Woods Pond and Schweitzer Dam - Approach

Channel Modified

__________um_ -poundyExecutive s __mar ___ BLASLAND amp BOUCK ENGINEERS PC

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 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

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

faci lity 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 major potential environmental impacts and

estimated schedules for project completion A summary of the findings of this

report follows

RIVER CHANNELIZATION

The River Channelization Alternative consists of re-routing portions of

the Housaton ic River by means of a new channel such that the river flow

- 1 shy

does not contact PCB-laden sediments (greater than 50 ppm) This new river

channel is intended to connect river segments with known non-PCB-Iaden

sediments while bypassing those segments with known PCB-laden sediments

The major engineering design and environmental considerations associated

with this alternative are summarized below

1 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a 4-6 week

period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove the Schweitzer Dam and to

drain Woods Pond the backwater areas and the overall river basin

Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

3 Determination of the acceptability of excavated soi Is as emban kment

materials

4 Determination of location of spoil or disposal areas for excess

excavated materials

5 Evaluation of environmental impacts upon the wetland areas

associated with Woods Pond and the backwater areas

6 Evaluation of construction activities upon local transportation

routes

7 Evaluation of impact upon recreational activities within the

Housatonic River Wildlife Management Area

8 Evaluation of the impacts of construction activities upon the local

public

- 2 shy

9 Evaluation of the reduction of groundwater and surface water

avai labi lity and

10 Evaluation of the increase of flood storage volume in the river basin

north of Woods Pond and the effects upon the downstream flood

storage volumes

It is estimated that the overall implementation schedule for the river

channelization alternative would be four to five 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 shy

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 a maintenance and 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 9f potential reduction in flood storage volume 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 six years

FLOW AND SEDIMENTATION CONTROL

The Flow and Sedimentation Control Alternative consists of modifying the

existing Schweitzer Dam below Woods Pond to further increase the ability of

- 4 shy

Woods Pond to act as a reliable and efficient sediment trap for PCB-laden

sediments 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 reservoi r drawdown system to

replace existing raceway

4 There would be no negative impacts on the Wildlife Management Area

or surrounding wetlands and

5 There would be positive impacts 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

- 5 shy

It is estimated that the overall implementation schedule for any of the

flow and sedimentation control options would be two-three 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 gO-Day Interim Reports and will include recommendations for those

alternatives to be evaluated in greater detail within the final 210-Day Report

- 6 shy

I l

BLASLAND amp BOUCK ENGINEERS PC

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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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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

- 7 shy

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

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SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 3: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

This Report was prepared for the General Electric Company by

Blasland amp Bouck Engineers PC 244 Westchester Avenue Suite 405 White Plains New York 10604

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

ACKNOWLEDGEMENT

Portions of this report were prepared by other consultants

Specifically Erseco Inc prepared Sections 3 and 7 Dravo Van Houten

Consulting Engineers assisted in preparation of Section 4 and OBrien amp Gere

Engineers Inc assisted in preparation of Sections 5 and 6 In addition

Erseco Inc assisted Blasland amp Bouck Engineers PC by providing general

consultation and review

TABLE OF CONTENTS

Acknowledgement Page No

Section Executive Summary

Section 2 Introduction 7

21 General 7

22 Purpose and Scope of This Work Effort 8

23 PCB-laden Sediments - Location and Description 8

Section 3 Overview of Applicable Regulations 10

31 Introduction 10

32 Regulatory Interests 10

33 Application of the National Contingency Plan 11

34 Previous Studies 12

Section 4 River Channelization Alternative 14

41 General 14

42 Description of Alternative 14

43 Pre-Construction and Construction Activities 16

44 Scheduling 16

45 Major Engineering Design Considerations 17

46 Major Potential Environmental Impacts 18

Section 5 In-situ Impoundment Alternative 21

51 General 21

52 Description of Alternative 21

53 Pre-Construction and Construction Activities 23

54 Scheduling 24

55 Major Engineering Design Considerations 24

56 Major Potential Environmental Impacts 25

Page No

Section 6 Flow and Sedimentation Control Alternative 28

61 General 28

62 Description of Alternative 28

63 Pre-Construction and Construction Activities 30

64 Scheduling 31

65 Major Engineering Design Considerations 32

66 Potential Environmental Impacts 33

Section 7 Application of Regulations 34

71 Introduction 34

72 Federal Regulations 35

73 State Regulations 37

74 Local Regulations Requirements 41

75 Summary 42

Section 8 Summary and Recommendations 44

81 Summary and Recommendations 44

References

Figures (Located Throughout Report)

General Study Area and Location of PCB-Laden

Sediments

2 Location of PCB Concentration

3 Plan of Channel - Ten Year Storm

4 Conceptual View of River 8efore Channelization

5 Conceptual View of River After Channelization

6 Woods Pond - Present Conditions

7 Woods Pond With Channel

8 Typical Cross Section

Figure 9 In-situ Impoundment - Armoring Typical Cross

Section

lOin-situ Impoundment - Chemical Stabilization

Typical Cross Section

11 Woods Pond and Schweitzer Dam - Existing

Conditions

12 Woods Pond and Schweitzer Dam - Lengthen and

Create a Multiple Stage Spillway

13 Woods Pond and Schweitzer Dam - Approach

Channel Modified

__________um_ -poundyExecutive s __mar ___ BLASLAND amp BOUCK ENGINEERS PC

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 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

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

faci lity 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 major potential environmental impacts and

estimated schedules for project completion A summary of the findings of this

report follows

RIVER CHANNELIZATION

The River Channelization Alternative consists of re-routing portions of

the Housaton ic River by means of a new channel such that the river flow

- 1 shy

does not contact PCB-laden sediments (greater than 50 ppm) This new river

channel is intended to connect river segments with known non-PCB-Iaden

sediments while bypassing those segments with known PCB-laden sediments

The major engineering design and environmental considerations associated

with this alternative are summarized below

1 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a 4-6 week

period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove the Schweitzer Dam and to

drain Woods Pond the backwater areas and the overall river basin

Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

3 Determination of the acceptability of excavated soi Is as emban kment

materials

4 Determination of location of spoil or disposal areas for excess

excavated materials

5 Evaluation of environmental impacts upon the wetland areas

associated with Woods Pond and the backwater areas

6 Evaluation of construction activities upon local transportation

routes

7 Evaluation of impact upon recreational activities within the

Housatonic River Wildlife Management Area

8 Evaluation of the impacts of construction activities upon the local

public

- 2 shy

9 Evaluation of the reduction of groundwater and surface water

avai labi lity and

10 Evaluation of the increase of flood storage volume in the river basin

north of Woods Pond and the effects upon the downstream flood

storage volumes

It is estimated that the overall implementation schedule for the river

channelization alternative would be four to five 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 shy

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 a maintenance and 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 9f potential reduction in flood storage volume 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 six years

FLOW AND SEDIMENTATION CONTROL

The Flow and Sedimentation Control Alternative consists of modifying the

existing Schweitzer Dam below Woods Pond to further increase the ability of

- 4 shy

Woods Pond to act as a reliable and efficient sediment trap for PCB-laden

sediments 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 reservoi r drawdown system to

replace existing raceway

4 There would be no negative impacts on the Wildlife Management Area

or surrounding wetlands and

5 There would be positive impacts 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

- 5 shy

It is estimated that the overall implementation schedule for any of the

flow and sedimentation control options would be two-three 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 gO-Day Interim Reports and will include recommendations for those

alternatives to be evaluated in greater detail within the final 210-Day Report

- 6 shy

I l

BLASLAND amp BOUCK ENGINEERS PC

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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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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

- 7 shy

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

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SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 4: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

ACKNOWLEDGEMENT

Portions of this report were prepared by other consultants

Specifically Erseco Inc prepared Sections 3 and 7 Dravo Van Houten

Consulting Engineers assisted in preparation of Section 4 and OBrien amp Gere

Engineers Inc assisted in preparation of Sections 5 and 6 In addition

Erseco Inc assisted Blasland amp Bouck Engineers PC by providing general

consultation and review

TABLE OF CONTENTS

Acknowledgement Page No

Section Executive Summary

Section 2 Introduction 7

21 General 7

22 Purpose and Scope of This Work Effort 8

23 PCB-laden Sediments - Location and Description 8

Section 3 Overview of Applicable Regulations 10

31 Introduction 10

32 Regulatory Interests 10

33 Application of the National Contingency Plan 11

34 Previous Studies 12

Section 4 River Channelization Alternative 14

41 General 14

42 Description of Alternative 14

43 Pre-Construction and Construction Activities 16

44 Scheduling 16

45 Major Engineering Design Considerations 17

46 Major Potential Environmental Impacts 18

Section 5 In-situ Impoundment Alternative 21

51 General 21

52 Description of Alternative 21

53 Pre-Construction and Construction Activities 23

54 Scheduling 24

55 Major Engineering Design Considerations 24

56 Major Potential Environmental Impacts 25

Page No

Section 6 Flow and Sedimentation Control Alternative 28

61 General 28

62 Description of Alternative 28

63 Pre-Construction and Construction Activities 30

64 Scheduling 31

65 Major Engineering Design Considerations 32

66 Potential Environmental Impacts 33

Section 7 Application of Regulations 34

71 Introduction 34

72 Federal Regulations 35

73 State Regulations 37

74 Local Regulations Requirements 41

75 Summary 42

Section 8 Summary and Recommendations 44

81 Summary and Recommendations 44

References

Figures (Located Throughout Report)

General Study Area and Location of PCB-Laden

Sediments

2 Location of PCB Concentration

3 Plan of Channel - Ten Year Storm

4 Conceptual View of River 8efore Channelization

5 Conceptual View of River After Channelization

6 Woods Pond - Present Conditions

7 Woods Pond With Channel

8 Typical Cross Section

Figure 9 In-situ Impoundment - Armoring Typical Cross

Section

lOin-situ Impoundment - Chemical Stabilization

Typical Cross Section

11 Woods Pond and Schweitzer Dam - Existing

Conditions

12 Woods Pond and Schweitzer Dam - Lengthen and

Create a Multiple Stage Spillway

13 Woods Pond and Schweitzer Dam - Approach

Channel Modified

__________um_ -poundyExecutive s __mar ___ BLASLAND amp BOUCK ENGINEERS PC

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 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

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

faci lity 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 major potential environmental impacts and

estimated schedules for project completion A summary of the findings of this

report follows

RIVER CHANNELIZATION

The River Channelization Alternative consists of re-routing portions of

the Housaton ic River by means of a new channel such that the river flow

- 1 shy

does not contact PCB-laden sediments (greater than 50 ppm) This new river

channel is intended to connect river segments with known non-PCB-Iaden

sediments while bypassing those segments with known PCB-laden sediments

The major engineering design and environmental considerations associated

with this alternative are summarized below

1 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a 4-6 week

period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove the Schweitzer Dam and to

drain Woods Pond the backwater areas and the overall river basin

Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

3 Determination of the acceptability of excavated soi Is as emban kment

materials

4 Determination of location of spoil or disposal areas for excess

excavated materials

5 Evaluation of environmental impacts upon the wetland areas

associated with Woods Pond and the backwater areas

6 Evaluation of construction activities upon local transportation

routes

7 Evaluation of impact upon recreational activities within the

Housatonic River Wildlife Management Area

8 Evaluation of the impacts of construction activities upon the local

public

- 2 shy

9 Evaluation of the reduction of groundwater and surface water

avai labi lity and

10 Evaluation of the increase of flood storage volume in the river basin

north of Woods Pond and the effects upon the downstream flood

storage volumes

It is estimated that the overall implementation schedule for the river

channelization alternative would be four to five 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 shy

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 a maintenance and 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 9f potential reduction in flood storage volume 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 six years

FLOW AND SEDIMENTATION CONTROL

The Flow and Sedimentation Control Alternative consists of modifying the

existing Schweitzer Dam below Woods Pond to further increase the ability of

- 4 shy

Woods Pond to act as a reliable and efficient sediment trap for PCB-laden

sediments 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 reservoi r drawdown system to

replace existing raceway

4 There would be no negative impacts on the Wildlife Management Area

or surrounding wetlands and

5 There would be positive impacts 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

- 5 shy

It is estimated that the overall implementation schedule for any of the

flow and sedimentation control options would be two-three 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 gO-Day Interim Reports and will include recommendations for those

alternatives to be evaluated in greater detail within the final 210-Day Report

- 6 shy

I l

BLASLAND amp BOUCK ENGINEERS PC

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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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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

- 7 shy

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

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SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 5: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

TABLE OF CONTENTS

Acknowledgement Page No

Section Executive Summary

Section 2 Introduction 7

21 General 7

22 Purpose and Scope of This Work Effort 8

23 PCB-laden Sediments - Location and Description 8

Section 3 Overview of Applicable Regulations 10

31 Introduction 10

32 Regulatory Interests 10

33 Application of the National Contingency Plan 11

34 Previous Studies 12

Section 4 River Channelization Alternative 14

41 General 14

42 Description of Alternative 14

43 Pre-Construction and Construction Activities 16

44 Scheduling 16

45 Major Engineering Design Considerations 17

46 Major Potential Environmental Impacts 18

Section 5 In-situ Impoundment Alternative 21

51 General 21

52 Description of Alternative 21

53 Pre-Construction and Construction Activities 23

54 Scheduling 24

55 Major Engineering Design Considerations 24

56 Major Potential Environmental Impacts 25

Page No

Section 6 Flow and Sedimentation Control Alternative 28

61 General 28

62 Description of Alternative 28

63 Pre-Construction and Construction Activities 30

64 Scheduling 31

65 Major Engineering Design Considerations 32

66 Potential Environmental Impacts 33

Section 7 Application of Regulations 34

71 Introduction 34

72 Federal Regulations 35

73 State Regulations 37

74 Local Regulations Requirements 41

75 Summary 42

Section 8 Summary and Recommendations 44

81 Summary and Recommendations 44

References

Figures (Located Throughout Report)

General Study Area and Location of PCB-Laden

Sediments

2 Location of PCB Concentration

3 Plan of Channel - Ten Year Storm

4 Conceptual View of River 8efore Channelization

5 Conceptual View of River After Channelization

6 Woods Pond - Present Conditions

7 Woods Pond With Channel

8 Typical Cross Section

Figure 9 In-situ Impoundment - Armoring Typical Cross

Section

lOin-situ Impoundment - Chemical Stabilization

Typical Cross Section

11 Woods Pond and Schweitzer Dam - Existing

Conditions

12 Woods Pond and Schweitzer Dam - Lengthen and

Create a Multiple Stage Spillway

13 Woods Pond and Schweitzer Dam - Approach

Channel Modified

__________um_ -poundyExecutive s __mar ___ BLASLAND amp BOUCK ENGINEERS PC

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 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

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

faci lity 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 major potential environmental impacts and

estimated schedules for project completion A summary of the findings of this

report follows

RIVER CHANNELIZATION

The River Channelization Alternative consists of re-routing portions of

the Housaton ic River by means of a new channel such that the river flow

- 1 shy

does not contact PCB-laden sediments (greater than 50 ppm) This new river

channel is intended to connect river segments with known non-PCB-Iaden

sediments while bypassing those segments with known PCB-laden sediments

The major engineering design and environmental considerations associated

with this alternative are summarized below

1 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a 4-6 week

period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove the Schweitzer Dam and to

drain Woods Pond the backwater areas and the overall river basin

Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

3 Determination of the acceptability of excavated soi Is as emban kment

materials

4 Determination of location of spoil or disposal areas for excess

excavated materials

5 Evaluation of environmental impacts upon the wetland areas

associated with Woods Pond and the backwater areas

6 Evaluation of construction activities upon local transportation

routes

7 Evaluation of impact upon recreational activities within the

Housatonic River Wildlife Management Area

8 Evaluation of the impacts of construction activities upon the local

public

- 2 shy

9 Evaluation of the reduction of groundwater and surface water

avai labi lity and

10 Evaluation of the increase of flood storage volume in the river basin

north of Woods Pond and the effects upon the downstream flood

storage volumes

It is estimated that the overall implementation schedule for the river

channelization alternative would be four to five 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 shy

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 a maintenance and 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 9f potential reduction in flood storage volume 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 six years

FLOW AND SEDIMENTATION CONTROL

The Flow and Sedimentation Control Alternative consists of modifying the

existing Schweitzer Dam below Woods Pond to further increase the ability of

- 4 shy

Woods Pond to act as a reliable and efficient sediment trap for PCB-laden

sediments 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 reservoi r drawdown system to

replace existing raceway

4 There would be no negative impacts on the Wildlife Management Area

or surrounding wetlands and

5 There would be positive impacts 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

- 5 shy

It is estimated that the overall implementation schedule for any of the

flow and sedimentation control options would be two-three 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 gO-Day Interim Reports and will include recommendations for those

alternatives to be evaluated in greater detail within the final 210-Day Report

- 6 shy

I l

BLASLAND amp BOUCK ENGINEERS PC

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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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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

- 7 shy

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

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SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 6: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

Page No

Section 6 Flow and Sedimentation Control Alternative 28

61 General 28

62 Description of Alternative 28

63 Pre-Construction and Construction Activities 30

64 Scheduling 31

65 Major Engineering Design Considerations 32

66 Potential Environmental Impacts 33

Section 7 Application of Regulations 34

71 Introduction 34

72 Federal Regulations 35

73 State Regulations 37

74 Local Regulations Requirements 41

75 Summary 42

Section 8 Summary and Recommendations 44

81 Summary and Recommendations 44

References

Figures (Located Throughout Report)

General Study Area and Location of PCB-Laden

Sediments

2 Location of PCB Concentration

3 Plan of Channel - Ten Year Storm

4 Conceptual View of River 8efore Channelization

5 Conceptual View of River After Channelization

6 Woods Pond - Present Conditions

7 Woods Pond With Channel

8 Typical Cross Section

Figure 9 In-situ Impoundment - Armoring Typical Cross

Section

lOin-situ Impoundment - Chemical Stabilization

Typical Cross Section

11 Woods Pond and Schweitzer Dam - Existing

Conditions

12 Woods Pond and Schweitzer Dam - Lengthen and

Create a Multiple Stage Spillway

13 Woods Pond and Schweitzer Dam - Approach

Channel Modified

__________um_ -poundyExecutive s __mar ___ BLASLAND amp BOUCK ENGINEERS PC

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 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

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

faci lity 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 major potential environmental impacts and

estimated schedules for project completion A summary of the findings of this

report follows

RIVER CHANNELIZATION

The River Channelization Alternative consists of re-routing portions of

the Housaton ic River by means of a new channel such that the river flow

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does not contact PCB-laden sediments (greater than 50 ppm) This new river

channel is intended to connect river segments with known non-PCB-Iaden

sediments while bypassing those segments with known PCB-laden sediments

The major engineering design and environmental considerations associated

with this alternative are summarized below

1 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a 4-6 week

period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove the Schweitzer Dam and to

drain Woods Pond the backwater areas and the overall river basin

Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

3 Determination of the acceptability of excavated soi Is as emban kment

materials

4 Determination of location of spoil or disposal areas for excess

excavated materials

5 Evaluation of environmental impacts upon the wetland areas

associated with Woods Pond and the backwater areas

6 Evaluation of construction activities upon local transportation

routes

7 Evaluation of impact upon recreational activities within the

Housatonic River Wildlife Management Area

8 Evaluation of the impacts of construction activities upon the local

public

- 2 shy

9 Evaluation of the reduction of groundwater and surface water

avai labi lity and

10 Evaluation of the increase of flood storage volume in the river basin

north of Woods Pond and the effects upon the downstream flood

storage volumes

It is estimated that the overall implementation schedule for the river

channelization alternative would be four to five 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 shy

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 a maintenance and 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 9f potential reduction in flood storage volume 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 six years

FLOW AND SEDIMENTATION CONTROL

The Flow and Sedimentation Control Alternative consists of modifying the

existing Schweitzer Dam below Woods Pond to further increase the ability of

- 4 shy

Woods Pond to act as a reliable and efficient sediment trap for PCB-laden

sediments 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 reservoi r drawdown system to

replace existing raceway

4 There would be no negative impacts on the Wildlife Management Area

or surrounding wetlands and

5 There would be positive impacts 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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It is estimated that the overall implementation schedule for any of the

flow and sedimentation control options would be two-three 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 gO-Day Interim Reports and will include recommendations for those

alternatives to be evaluated in greater detail within the final 210-Day Report

- 6 shy

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BLASLAND amp BOUCK ENGINEERS PC

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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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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

- 7 shy

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

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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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

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SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 7: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

Figure 9 In-situ Impoundment - Armoring Typical Cross

Section

lOin-situ Impoundment - Chemical Stabilization

Typical Cross Section

11 Woods Pond and Schweitzer Dam - Existing

Conditions

12 Woods Pond and Schweitzer Dam - Lengthen and

Create a Multiple Stage Spillway

13 Woods Pond and Schweitzer Dam - Approach

Channel Modified

__________um_ -poundyExecutive s __mar ___ BLASLAND amp BOUCK ENGINEERS PC

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 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

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

faci lity 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 major potential environmental impacts and

estimated schedules for project completion A summary of the findings of this

report follows

RIVER CHANNELIZATION

The River Channelization Alternative consists of re-routing portions of

the Housaton ic River by means of a new channel such that the river flow

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does not contact PCB-laden sediments (greater than 50 ppm) This new river

channel is intended to connect river segments with known non-PCB-Iaden

sediments while bypassing those segments with known PCB-laden sediments

The major engineering design and environmental considerations associated

with this alternative are summarized below

1 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a 4-6 week

period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove the Schweitzer Dam and to

drain Woods Pond the backwater areas and the overall river basin

Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

3 Determination of the acceptability of excavated soi Is as emban kment

materials

4 Determination of location of spoil or disposal areas for excess

excavated materials

5 Evaluation of environmental impacts upon the wetland areas

associated with Woods Pond and the backwater areas

6 Evaluation of construction activities upon local transportation

routes

7 Evaluation of impact upon recreational activities within the

Housatonic River Wildlife Management Area

8 Evaluation of the impacts of construction activities upon the local

public

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9 Evaluation of the reduction of groundwater and surface water

avai labi lity and

10 Evaluation of the increase of flood storage volume in the river basin

north of Woods Pond and the effects upon the downstream flood

storage volumes

It is estimated that the overall implementation schedule for the river

channelization alternative would be four to five 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

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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 a maintenance and 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 9f potential reduction in flood storage volume 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 six years

FLOW AND SEDIMENTATION CONTROL

The Flow and Sedimentation Control Alternative consists of modifying the

existing Schweitzer Dam below Woods Pond to further increase the ability of

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Woods Pond to act as a reliable and efficient sediment trap for PCB-laden

sediments 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 reservoi r drawdown system to

replace existing raceway

4 There would be no negative impacts on the Wildlife Management Area

or surrounding wetlands and

5 There would be positive impacts 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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It is estimated that the overall implementation schedule for any of the

flow and sedimentation control options would be two-three 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 gO-Day Interim Reports and will include recommendations for those

alternatives to be evaluated in greater detail within the final 210-Day Report

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I l

BLASLAND amp BOUCK ENGINEERS PC

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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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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 Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

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BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

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I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

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FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

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The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

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6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

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it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

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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 wi Idlife observation wi II be

significantly hindered

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In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

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SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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 a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 8: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

__________um_ -poundyExecutive s __mar ___ BLASLAND amp BOUCK ENGINEERS PC

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 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

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

faci lity 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 major potential environmental impacts and

estimated schedules for project completion A summary of the findings of this

report follows

RIVER CHANNELIZATION

The River Channelization Alternative consists of re-routing portions of

the Housaton ic River by means of a new channel such that the river flow

- 1 shy

does not contact PCB-laden sediments (greater than 50 ppm) This new river

channel is intended to connect river segments with known non-PCB-Iaden

sediments while bypassing those segments with known PCB-laden sediments

The major engineering design and environmental considerations associated

with this alternative are summarized below

1 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a 4-6 week

period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove the Schweitzer Dam and to

drain Woods Pond the backwater areas and the overall river basin

Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

3 Determination of the acceptability of excavated soi Is as emban kment

materials

4 Determination of location of spoil or disposal areas for excess

excavated materials

5 Evaluation of environmental impacts upon the wetland areas

associated with Woods Pond and the backwater areas

6 Evaluation of construction activities upon local transportation

routes

7 Evaluation of impact upon recreational activities within the

Housatonic River Wildlife Management Area

8 Evaluation of the impacts of construction activities upon the local

public

- 2 shy

9 Evaluation of the reduction of groundwater and surface water

avai labi lity and

10 Evaluation of the increase of flood storage volume in the river basin

north of Woods Pond and the effects upon the downstream flood

storage volumes

It is estimated that the overall implementation schedule for the river

channelization alternative would be four to five 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 shy

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 a maintenance and 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 9f potential reduction in flood storage volume 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 six years

FLOW AND SEDIMENTATION CONTROL

The Flow and Sedimentation Control Alternative consists of modifying the

existing Schweitzer Dam below Woods Pond to further increase the ability of

- 4 shy

Woods Pond to act as a reliable and efficient sediment trap for PCB-laden

sediments 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 reservoi r drawdown system to

replace existing raceway

4 There would be no negative impacts on the Wildlife Management Area

or surrounding wetlands and

5 There would be positive impacts 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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It is estimated that the overall implementation schedule for any of the

flow and sedimentation control options would be two-three 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 gO-Day Interim Reports and will include recommendations for those

alternatives to be evaluated in greater detail within the final 210-Day Report

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BLASLAND amp BOUCK ENGINEERS PC

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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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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 Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

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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 wi Idlife observation wi II be

significantly hindered

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In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

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SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 9: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

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

faci lity 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 major potential environmental impacts and

estimated schedules for project completion A summary of the findings of this

report follows

RIVER CHANNELIZATION

The River Channelization Alternative consists of re-routing portions of

the Housaton ic River by means of a new channel such that the river flow

- 1 shy

does not contact PCB-laden sediments (greater than 50 ppm) This new river

channel is intended to connect river segments with known non-PCB-Iaden

sediments while bypassing those segments with known PCB-laden sediments

The major engineering design and environmental considerations associated

with this alternative are summarized below

1 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a 4-6 week

period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove the Schweitzer Dam and to

drain Woods Pond the backwater areas and the overall river basin

Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

3 Determination of the acceptability of excavated soi Is as emban kment

materials

4 Determination of location of spoil or disposal areas for excess

excavated materials

5 Evaluation of environmental impacts upon the wetland areas

associated with Woods Pond and the backwater areas

6 Evaluation of construction activities upon local transportation

routes

7 Evaluation of impact upon recreational activities within the

Housatonic River Wildlife Management Area

8 Evaluation of the impacts of construction activities upon the local

public

- 2 shy

9 Evaluation of the reduction of groundwater and surface water

avai labi lity and

10 Evaluation of the increase of flood storage volume in the river basin

north of Woods Pond and the effects upon the downstream flood

storage volumes

It is estimated that the overall implementation schedule for the river

channelization alternative would be four to five 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 shy

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 a maintenance and 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 9f potential reduction in flood storage volume 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 six years

FLOW AND SEDIMENTATION CONTROL

The Flow and Sedimentation Control Alternative consists of modifying the

existing Schweitzer Dam below Woods Pond to further increase the ability of

- 4 shy

Woods Pond to act as a reliable and efficient sediment trap for PCB-laden

sediments 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 reservoi r drawdown system to

replace existing raceway

4 There would be no negative impacts on the Wildlife Management Area

or surrounding wetlands and

5 There would be positive impacts 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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It is estimated that the overall implementation schedule for any of the

flow and sedimentation control options would be two-three 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 gO-Day Interim Reports and will include recommendations for those

alternatives to be evaluated in greater detail within the final 210-Day Report

- 6 shy

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BLASLAND amp BOUCK ENGINEERS PC

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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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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

- 7 shy

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

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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 wi Idlife observation wi II be

significantly hindered

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In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

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SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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I [

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Page 10: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

does not contact PCB-laden sediments (greater than 50 ppm) This new river

channel is intended to connect river segments with known non-PCB-Iaden

sediments while bypassing those segments with known PCB-laden sediments

The major engineering design and environmental considerations associated

with this alternative are summarized below

1 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a 4-6 week

period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove the Schweitzer Dam and to

drain Woods Pond the backwater areas and the overall river basin

Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

3 Determination of the acceptability of excavated soi Is as emban kment

materials

4 Determination of location of spoil or disposal areas for excess

excavated materials

5 Evaluation of environmental impacts upon the wetland areas

associated with Woods Pond and the backwater areas

6 Evaluation of construction activities upon local transportation

routes

7 Evaluation of impact upon recreational activities within the

Housatonic River Wildlife Management Area

8 Evaluation of the impacts of construction activities upon the local

public

- 2 shy

9 Evaluation of the reduction of groundwater and surface water

avai labi lity and

10 Evaluation of the increase of flood storage volume in the river basin

north of Woods Pond and the effects upon the downstream flood

storage volumes

It is estimated that the overall implementation schedule for the river

channelization alternative would be four to five 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 shy

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 a maintenance and 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 9f potential reduction in flood storage volume 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 six years

FLOW AND SEDIMENTATION CONTROL

The Flow and Sedimentation Control Alternative consists of modifying the

existing Schweitzer Dam below Woods Pond to further increase the ability of

- 4 shy

Woods Pond to act as a reliable and efficient sediment trap for PCB-laden

sediments 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 reservoi r drawdown system to

replace existing raceway

4 There would be no negative impacts on the Wildlife Management Area

or surrounding wetlands and

5 There would be positive impacts 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

- 5 shy

It is estimated that the overall implementation schedule for any of the

flow and sedimentation control options would be two-three 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 gO-Day Interim Reports and will include recommendations for those

alternatives to be evaluated in greater detail within the final 210-Day Report

- 6 shy

I l

BLASLAND amp BOUCK ENGINEERS PC

I

r

I

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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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

- 7 shy

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 11: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

9 Evaluation of the reduction of groundwater and surface water

avai labi lity and

10 Evaluation of the increase of flood storage volume in the river basin

north of Woods Pond and the effects upon the downstream flood

storage volumes

It is estimated that the overall implementation schedule for the river

channelization alternative would be four to five 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 shy

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 a maintenance and 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 9f potential reduction in flood storage volume 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 six years

FLOW AND SEDIMENTATION CONTROL

The Flow and Sedimentation Control Alternative consists of modifying the

existing Schweitzer Dam below Woods Pond to further increase the ability of

- 4 shy

Woods Pond to act as a reliable and efficient sediment trap for PCB-laden

sediments 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 reservoi r drawdown system to

replace existing raceway

4 There would be no negative impacts on the Wildlife Management Area

or surrounding wetlands and

5 There would be positive impacts 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

- 5 shy

It is estimated that the overall implementation schedule for any of the

flow and sedimentation control options would be two-three 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 gO-Day Interim Reports and will include recommendations for those

alternatives to be evaluated in greater detail within the final 210-Day Report

- 6 shy

I l

BLASLAND amp BOUCK ENGINEERS PC

I

r

I

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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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

- 7 shy

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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I [

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Page 12: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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 a maintenance and 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 9f potential reduction in flood storage volume 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 six years

FLOW AND SEDIMENTATION CONTROL

The Flow and Sedimentation Control Alternative consists of modifying the

existing Schweitzer Dam below Woods Pond to further increase the ability of

- 4 shy

Woods Pond to act as a reliable and efficient sediment trap for PCB-laden

sediments 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 reservoi r drawdown system to

replace existing raceway

4 There would be no negative impacts on the Wildlife Management Area

or surrounding wetlands and

5 There would be positive impacts 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

- 5 shy

It is estimated that the overall implementation schedule for any of the

flow and sedimentation control options would be two-three 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 gO-Day Interim Reports and will include recommendations for those

alternatives to be evaluated in greater detail within the final 210-Day Report

- 6 shy

I l

BLASLAND amp BOUCK ENGINEERS PC

I

r

I

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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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

- 7 shy

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

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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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

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conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

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Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 13: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

Woods Pond to act as a reliable and efficient sediment trap for PCB-laden

sediments 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 reservoi r drawdown system to

replace existing raceway

4 There would be no negative impacts on the Wildlife Management Area

or surrounding wetlands and

5 There would be positive impacts 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

- 5 shy

It is estimated that the overall implementation schedule for any of the

flow and sedimentation control options would be two-three 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 gO-Day Interim Reports and will include recommendations for those

alternatives to be evaluated in greater detail within the final 210-Day Report

- 6 shy

I l

BLASLAND amp BOUCK ENGINEERS PC

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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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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

- 7 shy

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

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SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 14: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

It is estimated that the overall implementation schedule for any of the

flow and sedimentation control options would be two-three 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 gO-Day Interim Reports and will include recommendations for those

alternatives to be evaluated in greater detail within the final 210-Day Report

- 6 shy

I l

BLASLAND amp BOUCK ENGINEERS PC

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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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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

- 7 shy

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

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SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 15: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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BLASLAND amp BOUCK ENGINEERS PC

I

r

I

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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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

- 7 shy

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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I [

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Page 16: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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 SO ppr1) in the Housatonic River These three remedial action

al ternatives are as follows

1 River Channel ization

2 In-situ Impoundment and

3 Flow and Sedimentation Control

A previous report entitled the 4S-Day Interim Report (Reference 1)

dated October 1984 presented an evaluation of the sediment remova I and loca I

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 13S-Day Interim Report will further evaluate potentially adverse

environmental impacts and present additional engineering assessments of those

alternatives presented in the 4S-Day and 90-Day Interim Reports The

13S-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

- 7 shy

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

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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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

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FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

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1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r 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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66 Potential Envi ronmental 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 areas 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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Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

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conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

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State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

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TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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I [

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Page 17: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

22 Purpose and Scope of This Iork Effort

In July 1984 General Electric contracted Blasland amp Bouck Engineers

PC to prepare this Report including coordinating the efforts of Erseco

Inc OBrien amp Gere Engineers Inc and Dravo Van Houten Consulting

Engineers This Report contains the preliminary evaluation of the remaining

three remedial alternatives River Channelization In-situ Impoundment and

Flow and Sedimentation Control 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

- 8 shy

lgt Z o I r 0 o c o en lgt lgt G)-f --f rr1 -G)O t z ~ rn Z g ~

III N Z () en lgt TI~ ~~ g raquo~r J G)Om 0TJ 00 -i -i c~ lgt - 0-i 1Tl u z CJgt lt Zenr ITIOJ r rn TI ITIII r () () _ () III III m (J) 0 ITI -i g 0 z I --f U~2 ~ rc~ lt~ () III - 0 ITI 3 z -lt 0 0 lgt ()~ --t 0 eno ~ ITI lgtIE en en 3m r) Z --ishyll g 0 0 c jg 0 (J)rn O 0 z o ITIc lgt 0en -lt -lt

-3 -0 rt1 0

Z --fen Z

0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 18: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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0 ~ bull

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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I [

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Page 19: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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 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 may 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 4 2Q cif the 4S-Day Interim Report

- 9 shy

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

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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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

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1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

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conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

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State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 20: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

BLASLAND amp BOUCK ENGINEERS PC

SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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SECTION 3 - OVERVIEW OF APPLICABLE REGULATlmlS

31 Introduction

Assessment of the three remedial alternatives River Channel ization

In-situ Impoundment and Flow and Sedimentation Control 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 must be

addressed in the initial phases of a feasibility study to ensure that 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

- 10 shy

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

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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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 22: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

There are numerous federal and state statutes under which particular

actions associated with River Channel ization In-situ Impoundment and Flow

and Sedimentation Control may be regulated including but not limited to the

NCP the Clean Water Act (CVlA) and the Toxic Substances Control Act

(TSCA) at the federal level and the Massachusetts Wetlands Protection Act

(IVPA) at the state level Numerous local bylaws and ordinances also ~ust 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 Appl ication 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

- 11 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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 23: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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

- 12 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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 24: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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

- 13 shy

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 25: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

I

River Channelization Alternative

BLASLAND amp BOUCK ENGINEERS P C

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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I [

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Page 26: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

SECTION 4 - RIVER CHANNELIZATION ALTERNATIVE

41 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 ppm) The

objective of the river channelization al ternative 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 schedul ing Th locations and general characteristics of the sediments

subject to the river channelization alternative are presented within Section 2

of this Report

42 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 2 This new channel would be intended to connect

river segments with known non-PCB-Iaden sediments while bypassing those

segments with known PCB-laden sediments Construction of the new river

channel would require removal or bypassing of the existing Schweitzer Dam

The proposed route of the new channel is shown on Figure 3 The present

- 14 shy

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

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Page 27: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

SEWAGE FIGURE 2 TREATMENT

PLANT

o o

ltJ

LEGEND

Il SAMPLE LESS THAN eo PPM OF PC B I oc bull SAMPLE GREATER THAN amp0 PPM OF PCB

YOKUN BROOK ~

~ ~ _poundTELEPHONE

_ 00__ _ CABLE

lrf---HOUSATONIC RIVER

r

o o

1000 o 1000 2000 LOCATION OF PCB DraV CONCENTRATION Van Houten

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

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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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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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___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

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conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

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State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 28: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

Cravo

-I

lt

SEWAGE TREATMENT

P1ANT

1000 2000 OOO FEET

Va Houts

o o o o z ~ Z poundTELEPHONE ~ CABLE _ 0__ _

l)-f--HOUSATONIC RIVER

FIGURE 3

LEGEND

- FILL

1-wawMI EXCAVATION

2 2

IDEALIZED CROSS SEC T ION

PLAN OF CHANNEL

TEN YEAR STORM

1000 o

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 29: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

river conditions and the river conditions after completion of the proposed

channel are shown in Figures 4 and 5 respectively

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) with 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 would be removed and disposed of in

accordance with the 45-Day Report while non-PCB-Iaden 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 5 or removal and handling per the 45-Day Report

Figures 6 and 7 show an artists conception of the existing Woods Pond areamiddot

and the Woods Pond area with the proposed channel respectively

- 15 shy

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 30: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

FIGURE 4

- --

Of

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

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[

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Page 31: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

middot FIGURE 5

I

IDEALIZED

CROSS SECTION

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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I [

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Page 32: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

FIGURE 6

WOODS POND

Cravo PRESENT CONDITIONS Va Houts

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 33: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

FIGURE

WOODS POND

WITH CHANNELDrava Van Houten

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

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SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 34: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

43 Pre-Construction and Construction Activities

Pre-construction activities required to be performed in conjunction with

the river channelization alternative 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 Construction of temporary haul roads and staging areas

2 Dewatering of backwater areas (if necessary)

3 Construction of the channel including removal or bypassing of the

Schweitzer Pam clearing and grubbing excavation and placement

of embankments and riprap materials (if necessary) and

4 Spoil or disposal of excess excavated material

44 Scheduling

It is estimated that the overall schedule of the river channelization

alternative as described above would be four years The estimate is broken

down into the following components

1 Time to secure permitsfinal design 2-3 years

2 Construction activities 2 years

Total of 4-5 years

- 16 shy

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 35: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases As an example time

increases could be caused by permitting or weather-related delays

45 Major Engineering Design Considerations

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 Performance of a Drawdown Study during the summer of 1985 by

lowering the water level at the Schweitzer Dam for a four to six

week period to evaluate the associated effects upon the river basin

2 Development of a technique(s) to remove or bypass the Schweitzer

Dam and to drain Woods Pond the backwater areas and the overall

river basin

3 Consideration of the effects of constructing the bypass channel on

the upgradient and downgradient floodplain

4 Determination of the acceptability of excavated soils as embankment

materials

5 Determination of location of spoil or disposal areas for excess

excavated materials

- 17 shy

6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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6 Evaluation of potential flood storage volume impacts and

7 Evaluation of potential groundwater and surface water impacts

46 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

existing 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 These impacts will include the areas which are

directly altered by construction of the new river channel and the

abandoned riverbed and backwater areas It can be expected that

portions of the present river valley will be changed from a marsh-type

ecosystem to a drier grassland ecosystem This new resultant ecosystem

will establish itself as the valley dries out A number of stagnant pools

will occur in the deeper areas of the Housatonic River and Woods Pond

and these pools will be fed with waters from various streams and brooks

that contribute to the Housatonic River During the draining operations

- 18 shy

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

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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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

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FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

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conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

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implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

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State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 37: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

it is expected that the fish and aquatic species in the river sections

which are drained will be destroyed

Due to the large intended size of the new channel necessary to handle

storm events the channel bottom will likely dry out during low flow

periods of the summer This low flow rate in the new channel would

most likely not be able to support fish or the majority of other aquatic

species

2 Reduction of Groundwater and Surface Water Availability

The draining dewatering and re-routing of the eXisting bodies of water

will affect the recharge of waters to the groundwater system and will

affect availability of groundwater and surface water to local and

surrounding water users

3 Alteration of Flood Storage Capabilities

There will be a significant effect upon downstream floodplains and a

resultant increase of potential flood storage capabilities in the river

basin north of Woods Pond This is a result of conveying flood waters

more expeditiously since many of the constrictions associated with the

existing meandering river course wi II be eliminated by the construction

of the proposed channel and removal or bypassing of the Schweitzer

Dam

4 Construction of Access Roads and Increased Traffic

Vehicular traffic and increased traffic disturbance on local roads

throughout the project duration including congestion increased

probabi I ity of accidents noise and deteriorated road conditions

- 19 shy

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 38: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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 wi Idlife observation wi II be

significantly hindered

- 20 shy

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 39: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

In- situ Impoundment Alternative

BLASLAND amp BOUCK ENGINEERS PC

I I

I

r

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

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Page 40: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

SECTION 5 - IN-SITU IMPOUNDMENT ALTERNATIVE

51 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 el iminating 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 8 represents a conceptual cross section of the

eXisting river

52 Description of Alternative

Two options are being considered for the in-situ impoundment of the

PCpound3-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

- 21 shy

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

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Page 41: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

FIGURE a

PCB-LADEN SEDIMENTS

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 42: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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 layer would protect the

sand and gravel against movement during periods of increased water flow

velocities In the backwater areas of the river and within lVoods 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 9 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 wi II requi re dewatering followed by

placement of the armoring materials by conventional construction

equipment Additionallymiddot 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

- 22 shy

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

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Page 43: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

FIGURE 9

COBBLES (IF NECESSARy) 46 PCBLADEN SEDIMENTS

CRUSHED STONE (4-6)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETTS

HOUSATONIC RIVER STUDY

IN-SITU 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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

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Page 44: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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 are a few types of chemical stabilization techniques that can be

implemented without removing the sediments from the river or backwater

areas These methods have shown I imited success however additional

developmental work needs to be performed Figure 10 presents a

graphic presentation of this chemical stabilization alternative

53 Pre-Construction and Construction Activities

Pre-construction activities requi red to be performed in conjunction with

or following design would include the following

1 Submit documentation for and obtain ali 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

- 23 shy

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

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Page 45: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

FIGURE 10

bull ~

I I

STABILIZED PCB-LADEN SEDIMENTS(Top 3)

(NOT TO SCALE)

GENERAL ELECTRIC COMPANY PITTSFIELD MASSACHUSETIS

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

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Page 46: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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)

54 Scheduling

It is estimated that the overall schedule of the in-situ impoundment

alternative 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 2-3 years

2 Construction activities 2-3 years

Total of 4-6middot years

The estimated schedule presented above is optimistic Numerous delays

to the schedule may result in substantial time increases These time

increases may be a result of permitting or weather-related delays

55 Major Engineering Design Considerations

For each of the in-situ impoundment options 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 middotadditional major

engineering considerations that may be required

- 24 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

5 Identification of the strength required and methods to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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I [

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Page 47: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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 to obtain a

stable base for in-situ impoundment techniques and

6 Development of a maintenance and inspection program to evaluate

and maintain the effectiveness of in-situ impoundment techniques

56 Major Potential Environmental Impacts

The implementation of the in-situ impoundment alternative 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 Wildl ife

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

- 25 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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

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Page 48: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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

- 26 shy

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

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Page 49: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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

- 27 shy

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 50: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

___F_lo_w_ a_nd_ s_e_di_m_e_nt_a_ti_on_--~J Control Alternative BLASLAND amp BOUCK ENGINEERS PC

I I

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 51: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

SECTION 6 - FLOW AND SEDIMENTATION CONTROL ALTERNATIVE

61 General

This section will present the preliminary evaluation of the Flow and

Sedimentation Control Alternative being considered for the Schweitzer Dam

The objective of this alternative is to perform appropriate iFlprovements 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 envi ronmental impacts and scheduling

Figure 11 presents a graphic presentation of the existing Woods Pond and

Schweitzer Dam conditions

62 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 more 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

- 28 shy

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

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Page 52: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

FIGURE 11 iii= --

1 ~

shyWoods Pond amp ~gt~

Existing ~Chweltzer Damondltions

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

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Page 53: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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 date indicate that PCBs are in effect pulled from

Woods Pond and discharged from the by-pass canal into the HOLsatonic 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 amiddotssure 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 sedimentation 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

- 29 shy

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

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Page 54: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

end of the existing dam (Figure 12) 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 13) 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 constriction 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 th is area

63 Pre-Construction and Construction Activities

Pre~construction activities requi red to be performed for any of the flow

and sedimentation control options in conjunction with or following design

would include the following

- 30 shy

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

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Page 55: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

FIGURE 12

Woods Pond amp Schweitzer Dam Lengthenmiddot amp Create A Multiple Stage Spillway

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 56: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

FIGURE 13

~

Woods Pond amp S _ ~- - 0~ Approach Ch chweitzer Dam

_ anne I Modified

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 57: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

1 Submit documentation for and obtain allmiddot required permits

2 Obtain property rights-of-way from 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 sedimentation 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 stabi lity and

4 Implement flow and sedimentation control improvements which may

include earth and rock excavation foundation preparation grouting

and concrete or riprap placement

64 Scheduling

It is estimated that the overall schedule for any of the flow and

sedimentation control options would be two years The estimate is broken

down into the following components

- 31 shy

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

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Page 58: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

1 Time to secure permitsfinal design 1-2 years

2 Construction of dam improvements 1 year

Total of 2-3 years

The estimated schedule presented above is optimistic Various delays

such as permitting delays may result in substantial time increases

65 Major Engineering Design Considerations

For each of the flow and sedimentation control options 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 sedimentation control option

and

3 Development and design of a future reservoi r drawdown system to

replace the existing raceway This will be necessary to provide

emergency water level drawdown capabilities necessary for

maintenance of the dam

- 32 shy

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

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      2. barcode 512787
Page 59: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

66 Potential Envi ronmental 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 areas 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

- 33 shy

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 60: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

Application of Regulations BlASlAND amp 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 sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

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Page 61: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

SECTION 7 - APPLICATION OF REGULATIONS

71 Introduction

A complex regulatory network will govern the implementation of the

channelization in-situ impoundment and flow and sedimentation 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 wi II be detai led

Tables 1 and 2 (included at end of this section) present detai led outl ines

of the applicable federal and state regu lations For each regu lation 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 General comments

- 34 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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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Page 62: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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 worllt 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 anyone 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 sedimentation control alternative

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 channel ization 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

sedimentation 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

- 35 shy

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 63: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

conservation commissions under the Regulations for Wetlands and a Water

Quality Certificate issued by the State pursuant to regulations promulgated

under the Massachusetts Clean Water Act is required prior to the issuance of

a 404 Permit In addition a public hearing is optional

Toxic Substance and Control Act

According to the definition of disposal set forth in the PCB regulations

(40 CFR Part 761) promulgated under the Toxic Substance Control Act

(TSCA) the channelization in-situ impoundment and flow and sedimentation

control alternatives will be governed by the TSCA regulations Specifically

the regulation states that

Disposal means intentionally or accidentally to discard throwaway or

otherwise complete or terminate the useful life of PCBs and PCB Items

Disposal includes spills leaks and other controlled discharges of PCBs

as well as actions related to containing transporting destroying

degrading decontaminating or confining PCBs and PCB Items

The spoil or disposal of excavated sediments containing greater than 50

ppm PCBs may be required under the channelization alternative The in-situ

impoundment and flow and sedimentation control alternatives will consist of

disposal actions which will confine the PCB-laden sediments In addition

the flow and sedimentation control alternative may also require the spoil or

disposal of sediments containing greater than 50 ppm PCBs which may be

removed from the dam modification area Therefore the alternatives must

comply with TSCA regulations for PCB handling Accordingly materials

- 36 shy

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

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Page 64: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

containing greater than 50 ppm PCBs must 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 waiver 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

sedimentation control and channelization alternatives since these remedial

actions may require the removal 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

- 37 shy

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 65: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

Notice of Intent must be filed with the respective local conservation

commissions for each town which is affected A public hearing is mandatory

prior to the issuance of an Order of Conditions from the commissions for the

work to proceed This Order of Conditions is also required prior to the

issuance of the Federal 404 Permit previously discussed If there is a

disagreement over the Order of Conditions an appeal procedure is available

starting with the DEQE If a disagreement still exists an adjudicatory

hearing may be requested Finally in the event of a further disagreement a

possible waiver by the DEQE Commissioner may be obtained if certain criteria

can be satisfied It is anticipated that all of the alternatives will require the

filing of a Notice of Intent

Massachusetts Clean Water Act

I n addition to the Order of Conditions requi red prior to the issuance of

the Federal 404 Permit a Water Quality Certification from the DEQE Division

of Water Pollution Control stating that the proposed activities will not violate

any federal or state water quality regulations is required This certificate is

issued pursuant to the Certification for Dredging Dredged Material Disposal

and Filling in Waters regulations under the Massachusetts Clean Water Act

Waterways Act

Any work which will occur in waters which have been the recipient of

public money for flood control channelization or clearance projects is

regulated by the Waterways Licenses Regulations Since the Housatonic River

falls within this category it is subject to these regulations Therefore the

- 38 shy

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 66: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

implementation of any of the alternatives will require the filing of an

appl ication 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 (EI R)

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 amiddot greater than 20 percent

increase or decrease of impoundment capacity (flow and sedimentation 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 sedimentation 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

- 39 shy

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 67: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

of the proposed alternatives Therefore as stated in the Massachusetts

Hazardous Waste Regulations DEQE will retain approval authority over the

al ternate disposal method to be implemented

Mills Dams and Reservoirs Act

Under the Dam 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 (OEM) 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

- qO shy

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 68: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

Major Non-Appl icable 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 sedimentation 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 Iisting of all the local

regulatory agencies which may be involved depending upon the locations

affected by the remedial actions

- 41 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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 69: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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 sedimentation control alternative only

2 Hazardous Materials Transport Act Regulations for the transport of

Hazardous Wastes and Substances May be applicable to

channelization and flow and sedimentation control alternatives

3 Mills Dams amp Reservoirs Act Regulations currently under

promulgation Applicable to flow and sedimentation control

alternative only

In summary the following acts will be applicable to the implementation of

channel ization in-situ impoundment and flow and sedimentation control

alternatives bull

Federal

1 River amp Harbor Act

2 Clean Water Act

3 Toxic Substances Control Act

4 Hazardous Materials Transport Act

- 42 shy

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 70: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

State

1 Massachusetts Wetlands Protection Act

2 Waterways Act

3 Massachusetts Environmental Pol icy Act

4 Massachusetts Clean Water Act

5 Massachusetts Hazardous Waste Management Act

6 Mills Dams amp Reservoirs Act

7 Massachusetts Clean Air Act

- 43 shy

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 71: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

TABLE 1

FEDERAL

ill REGULATIONS

RELEVANT CRITICAL

INTERESTS

AGENCY APPOVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

River Act

r Harbor Permits (or Dams or Dikes 33 CFR 321

COE401i Permit EPA US Fish t Wlldll(e Dept of Marine

Fisheries

Application -Only applicable (or (low and sedimentation control al ternatlves

-Technical standards (or 11011 Permit 110 CFR 230

Structures or work In -Activities that alter COE404 Permit EPA Application -Technical standards for Navigable Waters or modl(y the course US Fish r Wildlife 404 Permit 40 CFR 230 33 CFR 322 condition location Dept of Marine

or capacity of a Fisheries navigable waterway

CWA Permit for Work In or -Discharge of fill COEQ04 Permit EPA Application -Public hearing (Optional) Discharges of Dredged or Fill Material Into

material US Fish t Wildlife Dept of Marine

-Technical standards for 404 Permit 110 CFR 230

Navigable Waters Fisheries 33 CFR 322 323

TSCA Disposal of Dredged Material t Municipal Sludge Containing PCBs

-Disposal of PCB-laden sediments

EPAApproval DEQE (If alternate disposal method requested)

Request for approvall waiver

-Approval of Regional Administrator

- TSCA definition of disposal

110 CFR 76160

Hazardous Materials TransportationAct

Transport of Hazardous Wastes amp Substances Jig CFR 172 Jig CFR 173510

-Vehicular requirements for transport of PCDs

DOTRegs EPA DEQE

-Only applicable to flow and sedlmenfation control and channelization aiternashytives I( removal of PCO-laden sediments required

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 72: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

TABLE 2

~

tpound RECULATIONS

RELEVANT CRITICAL

INTERESTS

ACENCYI APPROVAL

MECHANISM REVIEW

AUTHORITY SUBMITTAL COMMENTS

WPA Rt9ulation (or Wetlands 110 CMR 1000

-Alter land under waterways banks

-Change flood storage hydraulicscapacity

Local Conservation Commissions Order of

DEQE Notice o( Intent

-Performance standards -Public hearing (Mandatory) -Appeal to DEQE -Order of Conditions

-Alter bordering vegetated wetlands

Conditions -Required prior to Issuance of 11011 Permit

MCWA Cert Dredging Dredge Material Disposal Fill In

-Compliance with all water quality regulations

DEQE (WPC) Certification

Application -Public hearing (None) -Required prior to Issuance

o( 4011 Permit Waters 3 CMR 900

Waterways Act

Administration of Waterways licenses 310 CMR 900

-Work which occurs In waters which have been the recipient of public money (or

DEQE (Dlv of Wetlands 6 Waterway) I Permit

Application -Public hearing (Optional)

flood contrOl channelization or clearance projects

MEPA MEPA Regulations 301 middotCMR 1000

ENF Automatic =JTpounder $00 of bank -Olsposal gt10000 cy

MEPA Unit Approval

State Local ENF and EIR

of materTal -Structural alterations

of dam w1gt20 Inc or dec of ImPoundment capacity

EIR Automatic =stream relocation or

channelization of gt2000 (t

-Alter gt10 acres of wetland subject to c131 sIIO

Huardous Waste Management Act

Ma Hazardous Waste Regulations 310 CMR 30370 310 CMR 30501 310 CMR 30801

-PCB disposal requirements

-Transport and manl(est requirements

DEQEApproval -State refers to TSCA -Alternate disposal

method under TSCA requires DEQe approval

Mills Dams Re$ervolrs

Currently under promulgation

-Risk of life or property downstream

OEMPermit Application ~Only applicable to flow and sedimentation control

Act from dam failure alternatives -Drainage area

upstream In e)(Ce55 of one sq mile

-Height of dam greater than 10 (Ht above river bed at any point upstream

-Quantity of water impounded exceeds 1 million gallons

MCAA Air Pollution Control Regulation 310 CMR 700

-Fugitive all emissions

DEQE (Oiv of Air Pollution Control) Regs

-General r~ulatlons for any source of air pollution

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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  • 20120424091633559pdf
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  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 73: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

TABLE 3

LOCAL REGULATORY AGENCIES

a) Local Boards (General)

( 1 ) Se lectmen (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

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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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[

  • 20120424091633559pdf
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  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 74: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

TABLE 4

SUMMARY TABLE

Act

FEDERAL

River amp Harbor Act

CWA

TSCA

Hazardous Materials Transshyport Act

STATE

WPA

MCWA

Waterways Act

MEPA

Hazardous Waste Management Act

Mills Dams amp Reservoirs Act

MCAA

Regulations

Permits (or Oams or Dikes 33 CFR 321

Structures or Work in tlavigable Waters 33 CFR 322

Permit for Work In or Discharges of Dredged or Fi II Materials Into Navigable Waters 33 CFR 322 323

Disposal of Dredged Material amp Municipal Sludge Containing PCBs 40 CFR 761 60

Transport of Hazardous Wastes amp Substances 49 CFR 172 49 CFR 173510

ReQulations for Wetlands 310 CMR 1000

Cert Dredging Dredged Material Disposal amp Fill In Waters 314 CMR 900

Administration of Waterways Licenses 310 CMR 900

MEPA ReQulations 301 CMR 1000

Massachusetts Hazardous Waste Regulations 310 CMR 30370 30501 and 30801

Currently under Promulgation

Air Pollution Control Regulations 310 CMR 700

In-situ Flow and Sedl-Channelization Im~undment mentation -Contra

- - X

X X X

X X X

X X X

X - X

X X X

X X X

X X X

X X X

X X X

- - X

X X X

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 75: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

I

I

I [

Summary BLASLAND amp BOUCK ENGINEERS PC

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 76: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

SECTION 8 - SUMMARY AND RECOMMENDATIONS

81 Summary and Recommendations

This 90-Day Interim Report provides the first step in evaluating the

remedial alternatives of River Channel ization and In-situ Impoundment and

Flow and Sedimentation Control In addition this Interim Report identifies

the major engineering and potential environmental considerations of each 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 fo ena~le further screening utilizing the NCP criteria This evaluation of

the environmental impacts will be completed and submitted in the 13S-Day

Interim Report In addition the 13S-Day Interim Report will provide further

screening of the alternatives described in the 4S-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 13S-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 13S-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 4S-Day and 90-Day Interim

Reports

- 44 shy

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 77: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

Upon Regulatory Agency acceptance of the recommendations of the

135-Day Interim Report work will commence to provide a detailed evaluation

of the selected remedial option(s)

Respectfully submitted

BLASLAND amp BOUCK ENGINEERS PC

William H Bouck PE

Vice President

Prepared by

Blasland amp Bouck Engineers PC Robert K Goldman P E Dawn M Sheldon

Erseco Inc Roberta J Fine Ruth Geoffroy Robert Bouchard

OBrien amp Gere Engineers Inc Andrew N Johnson PE George C EI ias P E

Dravo Van Houten Phillip Sears

- 45 shy

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 78: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

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 I3lasland amp l30uck Engineers P C 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 71483

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

(

I r

I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 79: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

REFERENCES

1 Housatonic River Study 45-Day Interim Report Remedial Alternatives Evaluation Sediment Disposal Sites Prepared for the General Electric Company by I3lasland amp l30uck Engineers P C 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 71483

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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I [

[

[

  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787
Page 80: HOUSATONIC RIVER STUDY 90-DAY INTERIM REPORT, … · 2020-07-07 · This Report was prepared for the General Electric Company by: Blasland & Bouck Engineers, P.C. 244 Westchester

(

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  • 20120424091633559pdf
  • 20120424091914332
  • 20120424092012422
  • 20120424092120177
      1. barcodetext SDMS DocID 512787
      2. barcode 512787