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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
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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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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
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34 Previous Studies
The Waukegan Harbor site (Reference 4) and the New Bedford site
(Reference 5) are similar in nature to the Housatonic River in that sediments
at these locations are found to contain quantities of PCB-laden sediments
(greater than 50 ppm) requiring further review and evaluation of remedial
measures to contain or remove the material The quantities of PCBs at these
sites were much greater than those found in the Housatonic River however
the processes and decision-making structures which were used to develop the
regulatory and remedial action plans for these sites may be appropriate
during the Housatonic River remedial action planning
In the case of the OMC property at Waukegan Harbor the Assistant
Administrator for the Office of Solid Waste and Emergency Response at EPA
chose a remedial action that would in the Administrators opinion adequately
protect public health and the environment even though it did not fully comply
with TSCA A portion of the selected remedial action involved a combination
of technologies which included chemical stabilization of PCB-laden sediments
in-situ containment and surface water channelization Because of the
differences between Lake Michigan and the Housatonic River such as the
extent and location of PCB-laden sediment and lake vs river hydraulic and
geologic characteristics the specific design and proposed use of the
Waukegan Harbor remedial technologies may not be applicable in this instance
- 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
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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
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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
- 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
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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
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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
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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
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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
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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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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
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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
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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
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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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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
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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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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
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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
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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
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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
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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
- 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
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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
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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
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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
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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
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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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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
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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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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
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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
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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
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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
- 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
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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
- 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
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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
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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
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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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
- 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
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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
- 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 ~
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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 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
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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
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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
- 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
- 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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- barcodetext SDMS DocID 512787
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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
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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
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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__________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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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
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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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
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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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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
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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
- 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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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
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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
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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
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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
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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
- 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
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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
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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
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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
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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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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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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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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
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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
- 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
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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 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
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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
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chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
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5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
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___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
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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
- 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
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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
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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
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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
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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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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
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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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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
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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
- 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
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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
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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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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
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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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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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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
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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
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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
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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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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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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
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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
- 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
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
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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
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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
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chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
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5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
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___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
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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
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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
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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
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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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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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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
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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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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
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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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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
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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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- 20120424091633559pdf
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- barcodetext SDMS DocID 512787
- barcode 512787
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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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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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
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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
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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
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chemical additives This would include the temporary destruction and
significant alteration of local wetlands and the effects upon the
associated ecosystem This will affect not only the more permanent plant
and animal species but will also affect the nesting and migration of
other more temporary species such as waterfowl In addition by
covering or stabilizing existing sediments the bottom environment of the
affected river and associated bodies of water will be altered and provide
the basis for the establishment of a new ecological system differing from
the marshy wetland ecological system These impacts will include those
areas in which PCB-laden sediments are impounded as well as the
surrounding areas needed for access to the River and staging areas In
addition the newly established ecological system will be disrupted from
time to time during inspection and maintenance activities required by the
in-situ impoundment options
3 Impact of Construction Activities on the Local Public
Negative health and safety effects upon the local public due to the
potential health effects and nuisances which may result due to the noise
created by the construction equipment and the odors generated from the
exposure of dewatered highly organic backwater area sediments during
either armoring or chemical stabilization installation
4 Reduction of Flood Storage Volume
Minimal effect on floodplains and the reduction of potential flood storage
capabilities by performing construction activities in areas above the
normal water surface of the river and the backwater areas
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5 Construction of Access Roads and Increased Traffic
Minimal truck traffic and traffic disturbance on local roads throughout
the project duration including congestion increased probability of
accident noise and deteriorated road conditions
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___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
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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
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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
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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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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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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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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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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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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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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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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
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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
- 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
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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
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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
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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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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
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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
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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
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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
- 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
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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
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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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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
- 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
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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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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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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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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
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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
- 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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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
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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
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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
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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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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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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
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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
- 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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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
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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
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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
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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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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
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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
- 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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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
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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
- 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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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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___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
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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
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75 Summary
As shown in Table 4 (see end of Section) most of the referenced acts
and regulations pertain to all of the remedial alternatives presented within
this report with the following exceptions
1 River amp Harbor Act Regulations for permits for Dams or Dikes
Applicable to flow and 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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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
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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
- 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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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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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
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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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[
- 20120424091633559pdf
- 20120424091914332
- 20120424092012422
- 20120424092120177
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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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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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- 20120424091633559pdf
- 20120424091914332
- 20120424092012422
- 20120424092120177
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- barcodetext SDMS DocID 512787
- barcode 512787
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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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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- barcodetext SDMS DocID 512787
- barcode 512787
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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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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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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[
[
- 20120424091633559pdf
- 20120424091914332
- 20120424092012422
- 20120424092120177
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
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- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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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- 20120424091633559pdf
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- 20120424092120177
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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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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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
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
-
- barcodetext SDMS DocID 512787
- barcode 512787
(
I r
I [
[
[
- 20120424091633559pdf
- 20120424091914332
- 20120424092012422
- 20120424092120177
-
- barcodetext SDMS DocID 512787
- barcode 512787